PTAB

IPR2018-00660

SyncRo Soft SRL v. AltOva GmbH

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1. Case Identification

2. Patent Overview

  • Title: Automatic Fix for Extensible Markup Language Errors
  • Brief Description: The ’456 patent describes a software method for editing Extensible Markup Language (XML) documents. The system detects and analyzes well-formedness or validation errors, displays information about the error and its underlying causes to a user, and provides a set of possible actions to remedy the error.

3. Grounds for Unpatentability

Ground 1: Obviousness over XMLSpy2011, Maivald, and other references - Claims 1-12 are obvious over XMLSpy2011, Maivald, Hoskins, Lin, and/or Cucerzan.

  • Prior Art Relied Upon: XMLSpy2011 (a 2011 user manual by the Patent Owner), Maivald (a 2008 guidebook for Adobe InDesign), Hoskins (a 2010 guidebook for Adobe InDesign), Lin (Patent 7,657,832), and Cucerzan (Application # 2005/0210383).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that XMLSpy2011, a user manual for the Patent Owner’s own XML editor, taught the core limitations of independent claim 1, including detecting an error in an XML document, analyzing its cause, and displaying information to the user with a proposed fix. However, XMLSpy2011 taught providing only a single possible action. Maivald was introduced because it taught the benefit of providing a set of possible fixes for an XML error, allowing the user to choose the most appropriate one. For dependent claims, Hoskins was added to teach specific fixes, such as deleting an invalid element or inserting a required attribute with a default value. Lin was added to teach more advanced corrections, such as moving a misplaced element to a valid position (claim 4) and sorting suggested fixes based on statistical likelihood (claim 11). Finally, Cucerzan was introduced to teach the specific use of a Damerau-Levenshtein distance metric (claim 12) for sorting, a common algorithm for spell-checking.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine XMLSpy2011 with Maivald to improve the user experience by providing a list of possible fixes rather than just one. Maivald itself suggested that its built-in validator was basic and recommended using a more powerful, dedicated XML editor like XMLSpy. A POSITA would then incorporate the further teachings of Hoskins, Lin, and Cucerzan to add more sophisticated, well-known, and desirable error-correction features (e.g., specific fix types, sorting suggestions) to create a more robust and helpful commercial product.
    • Expectation of Success: A POSITA would have a high expectation of success in combining these teachings, as they all relate to well-understood features within the established field of XML editing and validation tools.

Ground 2: Obviousness over Lin, Adobe, and other references - Claims 1-12 are obvious over Lin in view of Adobe, XMLSpy2011, and/or Cucerzan.

  • Prior Art Relied Upon: Lin (Patent 7,657,832), Adobe (a 2007 user guide for Adobe InDesign CS3), XMLSpy2011 (a 2011 user manual), and Cucerzan (Application # 2005/0210383).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground used Lin as the primary reference, arguing it taught the fundamental method of validating a structured electronic document, identifying an error, and suggesting one or more corrective actions to a user. Petitioner argued that Lin's general method would be improved by incorporating the user interface features of existing commercial products. Adobe was added to teach a "Structure pane" UI that displays links to errors and allows users to make fixes. XMLSpy2011 was added to further teach displaying more detailed information, including links to corresponding schema definitions and relevant W3C specification sections, which Lin did not explicitly disclose. As in Ground 1, Cucerzan was added to supply the specific Damerau-Levenshtein distance metric for sorting corrections, as taught generally by Lin.
    • Motivation to Combine: A POSITA, starting with the error correction algorithms taught by Lin, would have been motivated to look to existing, popular software like Adobe InDesign and XMLSpy to implement a user-friendly interface. Combining Lin's backend logic with the well-established UI patterns from Adobe and XMLSpy represented a predictable path to creating a functional and commercially viable product. The motivation was to provide the user with not just suggestions, but also useful contextual links and information to help them understand and resolve errors efficiently.

4. Key Claim Construction Positions

  • "the working XML file": Petitioner argued this term lacked an antecedent basis in claim 1. Based on context and the specification, Petitioner proposed the broadest reasonable interpretation should be "the markup language document," which did have proper antecedent basis earlier in the claim.
  • "replacing the location causing the error... with the selected one of the possible actions": Petitioner contended this phrase was ambiguous because "actions" are not XML content that can "replace" a location. Based on the specification's examples (e.g., swapping elements), Petitioner proposed the term be construed as "modifying the markup language document at the location causing the error by carrying out the selected one of the possible actions."
  • "links to relevant information in an applicable W3C specification": Petitioner argued that the patentee's use of the plural "links" here, while using the singular "link" elsewhere in the same claim, was intentional. Supported by figures in the patent, Petitioner asserted this term should be construed to mean "at least two links to relevant information."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-12 of the ’456 patent as unpatentable under 35 U.S.C. §103.