PTAB

IPR2016-01300

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 ’309 patent relates to software routines for providing a "real time preview" of user commands within document editing programs. The disclosed method allows a user to visualize the effect of formatting changes, such as moving margins or guidelines, directly within the active document before the command is finalized.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 are obvious over QuarkXPress in view of WordPerfect, with Baker added for Claim 3.

  • Prior Art Relied Upon: QuarkXPress (a 1993 user guide), WordPerfect (a 1994 user guide), and Baker (Patent 6,185,591).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that QuarkXPress, a desktop publishing program, taught the core "real time preview" functionality for guidelines. It disclosed that a user could "view text resizing as you drag one of the handles of the text box," which provided an active preview of a guideline change. While QuarkXPress showed the visual effect, Petitioner asserted that WordPerfect taught the underlying mechanism of using formatting codes to control the document's appearance. WordPerfect explained that user actions, like changing a margin, cause the software to automatically insert a new formatting code and remove the old one. For claim 3, which adds pushing a command code onto an "Undo Stack," Petitioner argued that both QuarkXPress and WordPerfect taught basic undo functionality. Baker was cited to explicitly disclose the claimed implementation: recording document changes into a linked list of records in an "Undo Stack" for subsequent undo operations.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine QuarkXPress's dynamic visual preview with WordPerfect's well-known, code-based document structure. This combination represented a straightforward integration of a user-friendly front-end with a conventional back-end to achieve the predictable result of a live preview driven by underlying code changes. A POSITA would be further motivated to add Baker's undo stack implementation to provide a robust and commercially expected undo feature, which Baker itself suggested would be beneficial for programs like WordPerfect.
    • Expectation of Success: Combining these known software features was presented as a predictable application of existing techniques. A POSITA would have reasonably expected success in using WordPerfect’s code-manipulation methods to implement the visual preview shown in QuarkXPress, as using codes to render on-screen displays was standard practice.

Ground 2: Claims 1-3 are obvious over WordPerfect in view of IRIS, with Baker added for Claim 3.

  • Prior Art Relied Upon: WordPerfect (a 1994 user guide), IRIS (a 1996 user guide), and Baker (Patent 6,185,591).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground positioned WordPerfect as the base system, which already taught the use of formatting codes for margins, storing documents in memory, and an undo function. Petitioner argued that WordPerfect's own preview feature was limited to a static image in a separate dialog box. IRIS was introduced to supply the missing element of a real-time preview directly in the active document. The IRIS user guide explicitly stated that as a user adjusts margins by sliding markers on a ruler, "The text moves as you move the marker," demonstrating a live preview before the mouse button is released. For claim 3, Baker was again relied upon to teach the specific "Undo Stack" structure, supplementing WordPerfect's general undo capability with a detailed, conventional implementation.
    • Motivation to Combine: A POSITA would have been motivated to modify the existing WordPerfect software to incorporate the superior, in-document live preview taught by IRIS. This modification would follow a well-known industry trend of improving user interfaces with more dynamic feedback. It would have been an obvious improvement to replace WordPerfect's static preview with IRIS's more interactive functionality to enhance usability. The motivation to add Baker was to implement this desirable undo feature using one of a few known, predictable methods.
    • Expectation of Success: The proposed combination was merely the application of a known interface technique (IRIS's live preview) to a known software system (WordPerfect). Because WordPerfect already used formatting codes to control the document's display, a POSITA would have understood that updating these codes in real-time as a user dragged a margin marker would predictably result in the live preview taught by IRIS.

4. Key Claim Construction Positions

  • "real time preview": Petitioner argued this preamble term, to the extent it is limiting, should be construed to mean "a way of showing the impact of a change in a document prior to the user accepting that change." This construction was critical for distinguishing prior art that only showed a preview after a command was fully executed.
  • "guidelines" / "margin": Petitioner proposed constructions consistent with their ordinary meanings in document editing: "lines that aid in aligning text or other objects" and "a formatting feature defining a blank area at a vertical or horizontal edge of a page." These constructions were used to argue that features like text box borders (in QuarkXPress) and ruler markers (in IRIS) met the claim limitations.
  • "grab": Petitioner proposed the construction "position a cursor and hold a mouse button down." This interpretation is broad enough to encompass user actions like clicking and dragging the handle of a text box or a marker on a ruler bar, which are common interactions in the cited prior art.

5. Relief Requested

  • Petitioner requests institution of an IPR for claims 1-3 of Patent 6,731,309 and cancellation of those claims as unpatentable.