PTAB

IPR2017-01315

Bitdefender Inc v. Uniloc USA Inc

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1. Case Identification

2. Patent Overview

  • Title: Methods, Systems and Computer Program Products for Centralized management of Application Programs on a Network
  • Brief Description: The ’466 patent discloses methods and systems for managing the distribution of software over a client-server network. The invention involves a server that installs and maintains application programs, authenticates a user logging in from a client, and establishes a user-specific desktop interface at the client that displays icons for applications the user is authorized to access and execute on demand.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kasso and Raduchel - Claims 1, 7-8, 15-16, 22-23, and 35-36 are obvious over Kasso in view of Raduchel.

  • Prior Art Relied Upon: Kasso (Patent 5,832,505) and Raduchel (Patent 6,338,138).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kasso taught the core architecture of the challenged independent claims. Kasso described a client-server system where a user logs in, is authenticated, and is presented with a user interface (“Selector”) containing icons for various Java applets (application programs). Selecting an icon causes the corresponding applet to be downloaded from an HTTP server and executed on the client. Petitioner contended that this met the limitations of installing applications at a server, receiving a login, establishing a desktop interface with display regions, receiving a selection, and providing an application instance for execution.
    • Motivation to Combine: While Kasso taught providing an interface with applications, it did not explicitly teach filtering the displayed icons based on user-specific authorization. Raduchel taught a system where, after authentication, a token is returned indicating the services a user is authorized to use, and the browser then displays icons only for those specific services. A POSITA would combine Raduchel’s user-selective display with Kasso’s application delivery framework to improve system usability by simplifying the user interface and preventing users from encountering errors by selecting applications they are not authorized to use.
    • Expectation of Success: Combining a known authentication and filtering method (Raduchel) with a known application delivery system (Kasso) involved predictable software components and would have been straightforward for a POSITA.

Ground 2: Obviousness over Kasso, Raduchel, and Bennett - Claims 2, 17, and 30 are obvious over Kasso in view of Raduchel and Bennett.

  • Prior Art Relied Upon: Kasso (Patent 5,832,505), Raduchel (Patent 6,338,138), and Bennett (Patent 5,615,367).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Kasso and Raduchel to address dependent claims requiring the step of "maintaining application management information" at the server. Petitioner asserted that Kasso disclosed maintaining application and user "properties" (e.g., display fonts, window size) in "properties lists" on a server, which constituted a form of application management information. To the extent Kasso’s "properties list" was not considered a formal database, Bennett taught the use of a relational database management system (RDBMS) for storing and modeling information in a network environment.
    • Motivation to Combine: A POSITA would have found it obvious to use a database system as taught by Bennett to manage the "properties lists" described in Kasso. This would be a predictable design choice to provide a more organized, scalable, and efficient way to store, access, and maintain the user and application data, a common problem with a known solution in the art.
    • Expectation of Success: Implementing a database for data storage was a well-understood technique, and a POSITA would have reasonably expected success in applying Bennett’s database teachings to manage the data in the Kasso/Raduchel system.

Ground 3: Obviousness over Kasso, Raduchel, and Olsen - Claims 9, 24, and 37 are obvious over Kasso in view of Raduchel and Olsen.

  • Prior Art Relied Upon: Kasso (Patent 5,832,505), Raduchel (Patent 6,338,138), and Olsen (Patent 5,905,860).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring the additional steps of "determining a license availability" for a selected application and providing an "unavailability indication" if a license is not available. While the Kasso/Raduchel combination established a system for providing authorized applications, it lacked an explicit licensing mechanism. Olsen taught a server-based licensing system where a client requests a license from a License Server Provider (LSP), which determines if license units are available for that user and application. If not, the LSP returns a detailed error code to the client.
    • Motivation to Combine: A POSITA seeking to build a commercially viable, multi-user application delivery system would have been motivated to integrate a licensing management function. Olsen provided a known solution for this exact problem. Combining Olsen's licensing check would allow for the management of commercial software, a natural and foreseeable extension of the Kasso/Raduchel framework. A POSITA would perform this check after the user selects an application to limit license queries and reduce server load.
    • Expectation of Success: Integrating a server-side license check into an application delivery workflow was a known practice, and a POSITA would have expected predictable results from adding Olsen's licensing module to the combined Kasso/Raduchel system.

4. Key Claim Construction Positions

  • Petitioner dedicated significant argument to construing means-plus-function limitations, which are prevalent in the challenged claims. Key proposed structures included:
    • "means for establishing a user desktop interface": Construed as a Java-enabled web browser or desktop providing an operating environment, and an application launcher implemented as a Java applet downloaded to the client.
    • "means for maintaining application management information": Construed as code maintaining a database storing information such as user, software, device, and preference data.
    • "Installing": Petitioner argued that, based on the specification and prosecution history, "installing" should be construed as "storing" and is distinct from "configuring" or "registering" an application.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-2, 7-9, 15-17, 22-24, 30, and 35-37 of Patent 6,510,466 as unpatentable.