PTAB

IPR2017-01141

Microsoft Corp v. Kaufman Michael

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Petition
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1. Case Identification

2. Patent Overview

  • Title: System and Method for Generating Automatic User Interface for Arbitrarily Complex or Large Databases
  • Brief Description: The ’981 patent discloses a system that automatically generates a user interface (UI) for interacting with a relational database. The system interrogates the database schema to build a UI comprising distinct modes for database operations such as "browse," "search," "edit," and "add."

3. Grounds for Unpatentability

Ground 1: Claims 1-6 are obvious over Atkins in view of WebServer.

  • Prior Art Relied Upon: Atkins (a 1999 book titled Oracle Designer Generation) and WebServer (a 1999 article titled Oracle Designer WebServer Generator Tips and Tricks).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Atkins, which describes the Oracle Designer system, teaches automatically generating forms for interacting with a relational database. These forms inherently provide the functionality for creating (inserting), retrieving (querying), updating, and deleting data. However, Atkins primarily describes client-server applications. WebServer, an article describing a component of the same Oracle Designer system, teaches using the WebServer Generator to create dynamic web pages from the database definitions. WebServer explicitly discloses generating separate pages for different user interactions, such as a "Query Form," "View Form," "Insert Form," and a "Delete Confirmation Page." Petitioner contended that the combination of Atkins's form generation capabilities with WebServer's web-based, multi-page UI paradigm provides every element of the challenged claims, including the "output stream from a server" defining a UI with a "corresponding display format for each mode."
    • Motivation to Combine: A POSITA would combine these references because they describe complementary aspects of the same integrated Oracle Designer development environment. The motivation was to apply the known technique of web deployment (taught by WebServer) to the database application development system (taught by Atkins) to achieve the predictable result of a web-accessible database application. This combination would allow for the easy generation of fully functional web applications, enhance the UI, and tailor information presentation for each specific database operation.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involves using integrated components of a single, commercially available software suite (Oracle Designer) as intended to produce a web application, a well-understood and predictable outcome.

Ground 2: Claims 1-6 are obvious over Prague in view of Balter.

  • Prior Art Relied Upon: Prague (a 1997 book titled Access 97 Bible) and Balter (a 1999 book titled Mastering Microsoft Access 2000 Development).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Prague, which details the Microsoft Access database system, teaches the automatic generation of data-entry forms used to view, add, change, and delete database records. Prague also describes distinct UI formats for different modes of data manipulation through its various query design windows (e.g., select query, update query, append query, delete query), each with a unique interface and title bar. To supply the claimed "output stream from a server," Petitioner pointed to Balter, which teaches running Access applications from a file server across a network or generating "data access pages" to create web-based views of the database. Balter's data access pages are saved as HTML files and explicitly include buttons for adding, deleting, and saving records through a web browser.
    • Motivation to Combine: A POSITA would combine the teachings for several known benefits. First, applying Balter's suggestion of running Access from a file server to Prague's system would allow for the central administration of the database and reduce software licensing requirements, a predictable improvement. Second, a POSITA would be motivated to implement Balter's "data access pages" with Prague's system to advantageously allow internet and intranet users to view, update, add, and delete data from within a web browser, which was a well-known technique for improving database accessibility.
    • Expectation of Success: The combination represented the application of a known technique (creating web views of a database, per Balter) to a known system (the Access database management system of Prague) to achieve the predictable result of a web-enabled database.

4. Key Claim Construction Positions

  • "a user interface paradigm comprising a set of modes... and a corresponding display format for each mode" (claims 1, 4, 5): Petitioner argued this phrase means that a respective user interface exists for each of the specified modes: "create," "retrieve," "update," and "delete." This construction was central to the invalidity arguments, as the prior art allegedly shows distinct UIs for each of these specific database operations, even though the patent’s own specification focuses on different modes (browse, search, edit, add).
  • "managing said relationships across tables" (claims 1, 4, 5): Petitioner proposed this means "creating, revising, or manipulating a definition that specifies how one table is related to another." This construction was used to map prior art features like Oracle Designer’s Module Diagrams and Microsoft Access’s Relationship window, which graphically manage table relationships.
  • "automatically generating an end-user interface" (claims 1, 4, 5): Petitioner construed this simply as "automating the process of generating an end-user interface," arguing it was consistent with the specification’s description of on-the-fly UI generation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-6 of the ’981 patent as unpatentable.