PTAB

IPR2016-01084

Microsoft Corp v. Corel Software LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: REAL TIME PREVIEW
  • Brief Description: The ’483 patent describes software methods for providing a real-time preview of user-selected commands, such as font changes, within a document editing program. The purported invention involves applying a preview of a command to an entire selected portion of an active document before the user provides final confirmation, an alleged improvement over prior art systems that previewed changes on only a small sample of text.

3. Grounds for Unpatentability

Ground 1: Obviousness over CorelDRAW, IBM, WordPerfect, and Baker - Claims 1-4, 6, 7, 10-12, and 14 are obvious over the combination of four references.

  • Prior Art Relied Upon: CorelDRAW (CorelDRAW 7 Bible, May 1997), IBM (IBM Technical Disclosure Bulletin Vol. 34, Dec. 1991), WordPerfect (Mastering WordPerfect 8 2nd Edition, June 1997), and Baker (Patent 6,185,591).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of references taught every limitation of the challenged claims. The primary reference, CorelDRAW, disclosed a graphics and text editing program that provided previews for font changes in a separate pop-up window using text from the active document. Critically, CorelDRAW also taught providing real-time previews for other menu options (e.g., an "Offset" effect) directly within the active document before final user confirmation. The secondary reference, IBM, taught a "Pause Preview" technique for text editors where hovering the mouse cursor for a predetermined time would trigger a preview of a change directly in the active document, allowing the user to see the effect before committing. Petitioner contended that WordPerfect disclosed the conventional use of hidden "font command codes" to control text appearance, and Baker disclosed a standard implementation of an "undo stack" that records changes to a document for subsequent reversal, a common feature in editing software.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine the prior art teachings for predictable reasons. The primary motivation was to improve the user interface of a program like CorelDRAW by applying its own known technique of in-document previews to its font selection feature. A POSITA would have looked to IBM's "Pause Preview" concept as a known method for implementing this improvement, as it explicitly taught applying previews directly to an active document to give the user better visual feedback and certainty. Incorporating IBM's method would also solve the known problem of high computational cost associated with generating previews for every minor mouse movement. Finally, a POSITA would have naturally used the conventional techniques taught by WordPerfect (command codes) and Baker (undo stack) to implement the underlying font management and command reversal functionalities, as these were standard industry practices for such software.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because the combination represented the application of a known technique (in-document previewing) to a known system (a document editor with font selection) to achieve a predictable result (improved user feedback). The ’483 patent itself repeatedly admitted that the individual steps and routines were "known in the art," suggesting the claimed invention was merely a new combination of existing elements. The combination simply arranged old elements, with each performing its known function, leading to a predictable outcome.

4. Key Claim Construction Positions

  • "confirmation" (claims 1, 6, 14): Petitioner proposed this term be construed as an "indication of final acceptance by a user." This construction was central to the obviousness argument, as it distinguished the temporary, unconfirmed "preview" state from the final, user-accepted command. The prior art, particularly IBM, was argued to teach applying changes for preview purposes without receiving this final confirmation, which was the core of the claimed invention.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-4, 6, 7, 10-12, and 14 of the ’483 patent as unpatentable.