PTAB

IPR2019-00811

Microsoft Corp v. IPA Technologies Inc

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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 and method for collective task completion among distributed software agents. The system utilizes an inter-agent communication language (ICL) with distinct protocol layers to facilitate cooperative communication, problem-solving, and task management via a facilitator agent and an agent registry.

3. Grounds for Unpatentability

Petitioner asserted that the challenged claims are unpatentable under 35 U.S.C. §103. The core of the petition’s argument was that the patent examiner allowed the claims without being aware of the FIPA97 specification, a comprehensive prior art standard for inter-agent communication that allegedly disclosed the very features added during prosecution to overcome other rejections.

Ground 1: Obviousness over Kiss in view of FIPA97 - Claims 1, 26-29, 33, 45-47, and 86-89 are obvious over Kiss in view of FIPA97.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155) and FIPA97 (a 1997 specification from the Foundation for Intelligent Physical Agents).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kiss taught a computerized knowledge management system with the core architecture of the ’115 patent, including distributed intelligent agents, a "meta-agent" (facilitator) that formulates solution plans and dynamically interprets requests, and an agent registry. However, Kiss lacked a detailed, expandable, and platform-independent inter-agent language. FIPA97, a well-known public standard at the time, allegedly supplied these missing elements. Specifically, FIPA97 disclosed the FIPA Agent Communication Language (ACL), which featured a two-layer protocol (conversational and content), was defined by event types (performatives) and parameter lists, and included parameters that could "refine" the meaning of a message. For example, FIPA97's :receiver parameter could take a tuple of agent names to multicast a message, which Petitioner argued was analogous to the patent's solution_limit(N) example and satisfied the key limitation added during prosecution. FIPA97 also disclosed a content layer that supported goals, triggers, and data elements, as well as the use of arbitrarily complex goal expressions with logical nesting.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would be motivated to combine Kiss and FIPA97 because the agent system in Kiss required a communication protocol to function. FIPA97 provided a well-known, standardized, and robust solution (FIPA ACL) designed specifically to ensure interoperability among disparate agent systems. Combining the two would have been an obvious and efficient way to implement the necessary communication functionality in the Kiss architecture, representing a predictable combination of known elements for their intended purposes.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because FIPA97 was a public specification designed for integration, and its combination with an agent system like Kiss involved applying conventional technologies to achieve the predictable result of a communicating, cooperative agent system.

Ground 2: Obviousness over Kiss, FIPA97, and Moran - Claims 12-14 and 35-37 are obvious over Kiss in view of FIPA97 and Moran.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155), FIPA97 (1997 FIPA specification), and Moran (a 1997 publication on multimodal user interfaces in the Open Agent Architecture).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Kiss/FIPA97 combination and added Moran to address limitations related to handling user requests in a language different from the system's ICL (e.g., natural language). Petitioner contended that Moran disclosed a "UI Agent" that received requests in a "second language" (such as speech or pen-based input), selected a registered "recognition agent" to convert the input into a logical form, and forwarded it for processing. This functionality directly mapped to the limitations of claims 12-14 and 35-37, which required receiving a request in a second language, selecting a registered agent to convert it, and forwarding the request.
    • Motivation to Combine: A POSITA would be motivated to add Moran's teachings to the Kiss/FIPA97 system to provide more flexible and human-centered modes of user interaction, such as natural language processing. Moran explicitly encouraged incorporating pre-existing components into its architecture and emphasized multimodal interfaces for systems assembled from disparate agents. Integrating Moran's user interface technology would have been a known method for improving the usability of the underlying agent system.
    • Expectation of Success: Success was expected because Moran taught cooperation between independently developed agents and FIPA97 provided techniques to maximize interoperability. Combining Moran’s established user interface agents with the Kiss/FIPA97 agent framework was a straightforward integration of complementary technologies.

4. Key Claim Construction Positions

Petitioner argued that several claim terms were critical to the invalidity analysis, especially those added during prosecution to overcome prior art.

  • “a layer of conversational protocol”: Proposed as "a set of rules and standards governing the semantics of messages between agents." This construction emphasizes the meaning and interpretation of messages.
  • “a content layer”: Proposed as "a set of rules and standards governing the content embedded within a message." This distinguishes the substance of the message from its communication protocol.
  • “wherein the parameter lists further refine the one or more events”: Petitioner argued this phrase, added to distinguish the KQML language in the Nwana reference, should be construed to mean that a parameter list affects the meaning of the event itself (e.g., changing an "inform" to one agent into an "inform" to many), not merely providing contextual information like a sender or receiver ID.

5. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel claims 1, 12-14, 26-29, 33, 35-37, 45-47, and 86-89 of the ’115 patent as unpatentable.