PTAB

IPR2019-00810

Microsoft Corp v. IPA Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Software-Based Architecture for Communication and Cooperation Among Distributed Electronic Agents
  • Brief Description: The ’115 patent discloses a system for collective task completion among distributed software agents using a proprietary inter-agent communication language (ICL). The ICL is structured with distinct conversational and content protocol layers to facilitate cooperative problem-solving between agents.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kiss and FIPA97 - Claims 1, 4-10, 15, 29-32, and 38 are obvious over Kiss in view of FIPA97.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155) and FIPA97 (1997 Foundation for Intelligent Physical Agents v. 1.0 Specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kiss discloses the foundational framework of a multi-agent system but lacks the specific inter-agent communication language details recited in the claims. Kiss teaches a knowledge management system with cooperative intelligent agents, a meta-agent for formulating solution plans, and an agent registry for tracking agent capabilities. However, Petitioner contended that FIPA97, a comprehensive and publicly available specification for agent technologies, supplies the missing communication protocol details. FIPA97’s Agent Communication Language (ACL) was asserted to be an expandable, platform-independent language that provides the claimed "layer of conversational protocol" and "content layer." Specifically, FIPA97's performatives (e.g., inform, request) map to the claimed "event types," and its message parameters (e.g., :receiver, :protocol) map to the "parameter lists" that "further refine" the meaning of an event. FIPA97 also discloses expressing goals, triggers, and data elements within the content of a message, and supports constructing arbitrarily complex goal expressions with logical operators.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the agent system of Kiss with a standardized communication protocol like FIPA97 to address the known need for interoperability and efficient communication in multi-agent systems. Petitioner asserted Kiss and FIPA97 are analogous art, both directed to distributed agent architectures, making the combination logical and intuitive to improve the Kiss system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The combination involved applying a known, well-documented communication standard (FIPA97) to a known type of agent system architecture (Kiss) to achieve the predictable result of enabling robust communication between agents.

Ground 2: Obviousness over Kiss, FIPA97, and Cheyer - Claims 7, 16, and 39 are obvious over Kiss in view of FIPA97 and Cheyer.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155), FIPA97 (1997 FIPA v. 1.0 Specification), and Cheyer (a 1998 conference publication on multimodal tools).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the base combination of Kiss and FIPA97, adding Cheyer to teach specific limitations in dependent claims 7, 16, and 39. Petitioner argued that to the extent the primary combination did not explicitly teach these narrow features, Cheyer did. For claim 7, which requires the agent registry to include a "data declaration," Cheyer was cited for its disclosure of using data declarations in its agent registry. For claims 16 and 39, which require an "outgoing communications trigger," Cheyer was cited for describing a "communication trigger" that fires when "any agent sends" a message, thereby monitoring outgoing communication events and performing a defined action in response.
    • Motivation to Combine: A POSITA would be motivated to integrate Cheyer's techniques into the Kiss/FIPA97 system to enhance its functionality. Adding Cheyer's data declarations would provide more specific information in the agent registry, allowing a facilitator agent to more readily identify the best agent for a given sub-goal. Incorporating Cheyer's outgoing communication triggers would grant greater flexibility in monitoring and managing the system, for instance, by balancing communication loads.
    • Expectation of Success: Integrating Cheyer’s known data declaration and trigger mechanisms into the combined Kiss/FIPA97 agent system was presented as a straightforward application of conventional technologies to yield predictable improvements in system management and efficiency.

4. Key Claim Construction Positions

  • "layer of conversational protocol": Petitioner proposed this term be construed as "a set of rules and standards governing the semantics of messages between agents." This construction was central to mapping the detailed communication rules of the FIPA97 specification onto the claim language.
  • "wherein the parameter lists further refine the one or more events": Petitioner proposed this phrase be construed to mean "that a list of parameters associated with an event can refine the event by affecting the meaning of the event." This construction was critical, as this claim language was added during prosecution to distinguish prior art based on the KQML language. Petitioner argued that FIPA97's parameters, such as a :receiver parameter that enables multicasting or a :protocol parameter that changes a request from a simple offer to an auction bid, alter the fundamental meaning of the communicative act and thus meet this limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4-10, 15-16, 29-32, and 38-39 of the ’115 patent as unpatentable.