PTAB

IPR2019-00218

AltAMOnt Software Inc v. Sorna Corp

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1. Case Identification

2. Patent Overview

  • Title: MEDICAL DATA RECORDING SYSTEM
  • Brief Description: The ’408 patent describes a method for automating the process of recording medical data onto physical media like CDs. The system receives medical image data in DICOM format, parses patient and study information, and then records the images, along with viewing software, onto a CD, which is then automatically labeled with the extracted information.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kahle, DICOMView, and MicroTech - Claims 1-2, 6-11, and 14-19 are obvious over Kahle in view of DICOMView and further in view of MicroTech.

  • Prior Art Relied Upon: Kahle (Patent 5,518,325), DICOMView (Heartlab's 1998 DICOMView User's Guide), and MicroTech (MicroTech User's Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references teaches all limitations of the challenged claims. Kahle taught a generic method for automatically recording data onto a CD and printing a label with "title information" extracted from that data stream. While Kahle was field-agnostic, DICOMView specifically taught a system for the medical field that records DICOM images and viewing software onto a CD and allows users to retrieve patient and study information. Petitioner contended that combining Kahle's automation with DICOMView's medical-specific application would render the core process obvious. To address the claimed limitation of "noting the end of the received medical data," Petitioner introduced MicroTech, which taught using a timer and a timeout period (disclosing the same 30-second default as the patent) to detect the end of a data stream before recording.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Kahle and DICOMView to apply a known automation technique (Kahle's automated labeling) to a known system (DICOMView's medical image CD creation) to achieve the predictable result of an automated medical data recording system. A POSITA would further incorporate MicroTech's timeout feature as it represented a well-known, obvious solution to the common problem of determining when an incoming data stream is complete before initiating a recording job.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying known techniques (automated labeling, timeout detection) to a known system (medical imaging) for their intended purposes, leading to predictable improvements in efficiency and reliability.

Ground 2: Obviousness over Kahle, DICOMView, MicroTech, and Farrell - Claims 3-5, 12, and 13 are obvious over Kahle in view of DICOMView and MicroTech, and further in view of Farrell.

  • Prior Art Relied Upon: Kahle (Patent 5,518,325), DICOMView (Heartlab's 1998 DICOMView User's Guide), MicroTech (MicroTech User's Manual), and Farrell (Patent 5,717,841).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated all arguments from Ground 1 and added Farrell to address claims related to data management, specifically backing up, storing, and deleting jobs and patient information. Farrell disclosed a method for managing inactive print jobs, including operator-specified actions like automatic archiving (backing up) or deleting jobs upon the occurrence of a triggering event. Petitioner argued that Farrell taught the specific data management functions recited in claims 3-5, 12, and 13, such as backing up medical data (claim 3), storing a job after creation (claim 4), deleting a job after submission (claim 5), and automatically deleting or keeping patient information (claims 12-13).
    • Motivation to Combine: A POSITA, having developed the system taught by the combination in Ground 1, would face the subsequent, predictable problem of managing completed jobs and the associated data. Farrell was directly pertinent to this problem. A POSITA would therefore be motivated to incorporate Farrell's teachings on job archiving and deletion into the combined Kahle/DICOMView/MicroTech system to improve data management, conserve storage space, and create backups of critical medical information, all of which are desirable and predictable improvements.
    • Expectation of Success: Integrating Farrell's data management features into the base system would have been a straightforward application of a known technique to solve a known problem, with a high expectation of achieving the predictable result of a more robust data recording system with archiving and deletion capabilities.

4. Key Claim Construction Positions

  • "parsing" (Claim 1) and "extracting" (Claim 14): Petitioner proposed these terms should be interpreted as simply "retrieving" data from a data source. This construction supports the argument that Kahle's teaching of extracting "title information" is equivalent to the patent's parsing/extracting of patient information.
  • "noting the end of the received medical data information": Petitioner argued this should be construed as "observing the end of the received medical data information." This broad construction was critical for asserting that MicroTech's method of using a timeout period to detect a period of silence in a data stream met this limitation.
  • "autoloader control software": Proposed as "software that automatically facilitates the moving and recording of a CD and printing a label thereon." This construction aligns the claim term with the functionality described in Kahle's automated CD handling and labeling system.
  • "job": Proposed as a "specified amount of processing by a computer." This construction allows Petitioner to argue that the processes described in Kahle and DICOMView, even if not explicitly called a "job," meet the claim limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-19 of Patent 7,965,408 as unpatentable.