PTAB

IPR2019-00735

Google LLC v. IPA Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Computing Environment
  • Brief Description: The ’128 patent relates to a mobile, ambient computing environment for a user away from their desk. The system uses an "Open Agent Architecture" where communication and cooperation between various electronic agents (e.g., GPS agents, application agents) are brokered by one or more "facilitator" agents that match service requests with agent capabilities.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1, 2, 20, and 21 over Nodine, Steiner, Finin, and Bayardo

  • Prior Art Relied Upon: Nodine (a 1998 paper on the InfoSleuth agent infrastructure), Steiner (Patent 5,528,248), Finin (a 1997 book chapter on the KQML agent communication language), and Bayardo (a 1997 paper on the InfoSleuth architecture).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination teaches all limitations of independent claim 1. Nodine, the primary reference, was asserted to teach a collaborative community of distributed electronic agents that communicate using an interagent communication language (ICL) built on KQML. Nodine’s "broker agent" receives advertised capabilities from other agents to perform semantic matchmaking. Petitioner contended that adding a mobile computing environment, as taught by Steiner’s Personal Digital Assistant (PDA) with GPS capabilities, would have been a simple and predictable modification to Nodine's agent system. Finin was used to explicitly teach an "agent registry" maintained by a facilitator for matchmaking, a feature Petitioner argued was an obvious implementation of Nodine's broker agent concept. The combination was also alleged to teach a facilitator agent that coordinates tasks by delegating goals to agents based on their registered capabilities, and service-providing agents that communicate bidirectionally with the facilitator. Bayardo, which describes an implementation of Nodine's InfoSleuth system, was used to teach user interface agents that generate ICL goals corresponding to a user's request.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve existing technologies. A POSITA would have been motivated to apply the mobile computing and location-awareness features of Steiner to Nodine's distributed agent system to provide useful, location-based information retrieval for mobile users. Since Nodine cites and builds upon the KQML language described in Finin, a POSITA would naturally look to Finin for details on implementing features like an agent registry and facilitator-based coordination. Similarly, because Bayardo describes a specific implementation of the InfoSleuth system discussed in Nodine, a POSITA would consult it for details on user interaction and goal generation.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved applying known mobile computing technologies (Steiner) to a known agent architecture (Nodine) using well-understood implementation details for agent registries and user interfaces (Finin, Bayardo). The integration was portrayed as a predictable combination of known elements.

Ground 2: Obviousness of Claim 5 over Nodine, Steiner, Finin, Bayardo, and Malone

  • Prior Art Relied Upon: The combination from Ground 1, further in view of Malone (a 1997 book chapter on agents for information sharing).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Malone to the primary combination to teach the limitations of claim 5: "conditional triggers" associated with service agents that enable the community to "proactively interact with the user." Petitioner argued Malone explicitly discloses software agents that have a "'Trigger' action that triggers them to start running" and systems that respond automatically to messages based on "if-then" rules. These rules, which constitute conditional triggers, allow for proactive interaction with a user, such as automatically sorting messages or flagging overdue tasks.
    • Motivation to Combine: A POSITA would combine Malone with the base combination to add useful proactive functionality to the agent system. Malone addresses the same field of software agents for information sharing and coordination as Nodine. A POSITA would have been motivated to incorporate Malone's well-known "if-then" trigger logic to enable the agent community to perform tasks automatically in response to certain conditions, enhancing its utility and efficiency.
    • Expectation of Success: Implementing conditional triggers using if-then logic was a fundamental and well-understood concept in computer science. A POSITA would have readily known how to integrate such logic into the agent system with a high expectation of success.

Ground 3: Obviousness of Claims 7-9 and 11 over Nodine, Steiner, Finin, Bayardo, and Obradovich

  • Prior Art Relied Upon: The combination from Ground 1, further in view of Obradovich (Patent 6,009,355).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Obradovich to teach the limitations of claims 7-9 and 11, which relate to controlling automotive electronic devices. Petitioner asserted that Obradovich teaches a vehicle user interface with an "electronic device control panel" for controlling functions like a radio/CD player, cruise control, and lights. It also discloses a communication center panel with a telephony interface that is responsive to voice commands.
    • Motivation to Combine: A POSITA implementing a mobile agent system for a user would consider common mobile environments, such as an automobile. Obradovich provides a detailed example of a user interface for controlling various systems within a car. A POSITA would be motivated to integrate the automotive control features of Obradovich into the mobile agent system of the primary combination to provide a useful, centralized control interface for in-vehicle functions, leveraging the existing agent architecture.
    • Expectation of Success: Integrating a control panel interface for automotive devices into the broader mobile computing agent framework was argued to be a straightforward application of known user interface design principles to a new, but predictable, context.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the core combination of Nodine, Steiner, Finin, and Bayardo, with further additions of Tamai (for multimodal maps based on site type), Trovato and Sharman (for text-to-speech spoken directions), and Logan (for voice-controlled email and voicemail interfaces).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 and 20-21 of the ’128 patent as unpatentable.