Microsoft Corp v. Bradium Technologies LLC

1. Case Identification

• Case #: IPR2016-00448
• Patent #: 7,908,343
• Filed: January 11, 2016
• Petitioner(s): Microsoft Corporation
• Patent Owner(s): Bradium Technologies LLC
• Challenged Claims: 1-20

2. Patent Overview

• Title: System and Methods for Optimized Image Delivery Over Limited Bandwidth Communication Channels
• Brief Description: The ’343 patent discloses a client-server system for efficiently delivering large-scale images, such as geographic maps, over networks with limited bandwidth. The system pre-processes a source image into a series of derivative images of progressively lower resolution, which are subdivided into "parcels" (tiles) and stored on a remote server for on-demand retrieval by a client device.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Reddy in view of Hornbacker.

• Prior Art Relied Upon: Reddy ("TerraVision II: Visualizing Massive Terrain Databases in VRML," an IEEE journal article from Mar./Apr. 1999) and Hornbacker (International Publication No. WO 99/41675).
• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that the combination of Reddy and Hornbacker taught all limitations of the challenged claims. Reddy described the TerraVision II system, which addressed the same problem as the ’343 patent: visualizing massive terrain databases over the web on standard computers. Reddy taught using a multi-resolution "pyramid" of image tiles organized in a quad-tree structure, enabling progressive, "coarse-to-fine" loading of map data based on the user's 3D viewpoint. This disclosed the core architecture of pre-processing images into multiple resolutions (claim 1, element D), subdividing them into arrays of tiles (element E), using fixed pixel resolutions for tiles (element F), and storing them in a defined quad-tree configuration (element J).

  • Petitioner asserted that while Reddy provided the overall system, Hornbacker supplied specific, complementary teachings. Hornbacker described a client-server system for displaying large tiled images over the web, explicitly teaching the use of GIF compression with a typical 4:1 ratio to reduce file size (mapping to claim 1, element I). Hornbacker also taught using URLs that uniquely identify tiles by their scale (resolution) and position (row/column), providing a concrete implementation for the tile retrieval mechanism described more generally in Reddy. Dependent claims were allegedly met by Reddy’s disclosure of using terrain tiles with topography and text overlays (claim 2), implementing the system on a laptop (claim 3), and using multi-threading to render images (claims 12 and 20).

  • Motivation to Combine (for §103 grounds): A Person of Ordinary Skill in the Art (POSITA) would combine Reddy and Hornbacker because both references were in the same field and addressed the identical problem of efficiently delivering large-scale image data over limited bandwidth networks. A POSITA examining Reddy’s TerraVision system, which focused on optimizing bandwidth through multi-resolution tiling, would be motivated to incorporate the explicit and well-known technique of image compression taught by Hornbacker to achieve further, predictable improvements in network performance. The combination was presented as an application of a known technique (Hornbacker's compression) to a known system (Reddy's mapping platform) to yield predictable results.

  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because both systems relied on similar and conventional internet technologies (client-server architecture, web browsers, HTTP, URLs). Integrating Hornbacker's tile compression and URL-based addressing scheme into Reddy's system was argued to be a straightforward modification for anyone skilled in the art of network graphics delivery.

4. Key Claim Construction Positions

• "Data Parcel": Petitioner proposed construing this term under the Broadest Reasonable Interpretation (BRI) standard as "data that corresponds to an element of a source image array." This construction was argued to be consistent with the specification and allowed the term to map directly to the "tiles" disclosed in both Reddy and Hornbacker.
• "A mesh": For claim 13, Petitioner proposed construing "mesh" as "a collection of polygons." This construction aligned with standard computer graphics terminology and mapped to Reddy’s disclosure of using a polygonal representation of a digital elevation model onto which image data is texture-mapped.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that institution was proper because the petition raised questions of patentability that had not been previously considered by the Patent Office or the Board. It was noted that a prior inter partes review (IPR) petition on the same patent (IPR2015-01434) had been denied. However, Petitioner stressed that this new petition was based on a different ground, relying on Reddy as the primary reference, which was not presented in the first IPR or during the original examination. This implicitly argued against a discretionary denial under 35 U.S.C. §325(d), as the current petition presented new prior art and arguments.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’343 patent as unpatentable.