PTAB

IPR2019-00812

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 and method for cooperative task completion among distributed software agents. The system utilizes a proprietary, expandable "Interagent Communication Language" (ICL) that features two distinct protocol layers: a "layer of conversational protocol" defining message semantics and a "content layer" for goals, triggers, and data.

3. Grounds for Unpatentability

Ground 1: Claims 1, 15, 18-19, 29, 34, 38, and 41-42 are obvious over Kiss in view of FIPA97.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155) and FIPA97 (1997 FIPA v. 1.0 Specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kiss discloses the foundational architecture of the challenged claims, including a knowledge management system with a plurality of cooperative, distributed intelligent agents, an agent registry, and a "meta-agent" that functions as a facilitator to dynamically interpret requests and formulate solution plans. However, Kiss lacks specific detail on the inter-agent communication language. FIPA97, a well-known industry standard for agent interoperability, allegedly supplies the missing language elements. FIPA97's Agent Communication Language (ACL) is described as an expandable, platform-independent language that provides both the claimed "layer of conversational protocol" (through its use of performatives, or "communicative acts," and associated parameters) and the "content layer" (through its rules for encoding goals, triggers, and data within messages).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have recognized that a distributed agent system like Kiss requires a common, robust communication protocol to function effectively. FIPA97 was a publicly available, standardized solution designed specifically to provide interoperability for such systems. A POSITA would combine the standardized FIPA97 communication protocol with the agent system architecture of Kiss as a predictable, common-sense implementation to achieve efficient and interoperable communication between agents.
    • Expectation of Success: The combination involved applying a known communication standard (FIPA97) to a known type of system (Kiss) to achieve the predictable result of functional inter-agent communication. Both were well-known, conventional technologies in the field, ensuring a high expectation of success.

Ground 2: Claims 17, 20-25, 40, 43, and 44 are obvious over Kiss in view of FIPA97 and Cohen.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155), FIPA97 (1997 FIPA v. 1.0 Specification), and Cohen (a 1994 publication titled "An Open Agent Architecture").
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Kiss/FIPA97 combination to address the specific "trigger" limitations in the dependent claims. Petitioner asserted that while FIPA97 teaches basic trigger functionality, Cohen provides more explicit teachings that satisfy the claim limitations for incoming communications triggers that are installed and executed on facilitator or service-providing agents. Cohen discloses a "Blackboard server" that functions as a facilitator agent, on which triggers can be placed to monitor events (e.g., "when mail arrives... get it to me"). This system demonstrates monitoring for a specific incoming communication event, and in response, performing a defined action, directly mapping to the language of claims like 17 and its dependents.
    • Motivation to Combine: A POSITA seeking to implement more complex trigger mechanisms in the Kiss/FIPA97 system would have been motivated to incorporate the teachings of Cohen. Cohen's Blackboard architecture was analogous to the facilitator/meta-agent concept in Kiss and FIPA97, and Cohen itself encouraged integrating components from other systems. Combining Cohen's sophisticated trigger-handling functionality with the Kiss/FIPA97 framework was an obvious design choice to enhance the system's capabilities, representing an arrangement of old elements for their known purposes.
    • Expectation of Success: The combination involved integrating a known trigger mechanism (from Cohen) into a facilitator agent within a known agent framework (Kiss/FIPA97). Given the analogous functions of the facilitator agents across the references, a POSITA would have expected this integration to be successful without undue experimentation.

4. Key Claim Construction Positions

Petitioner proposed constructions for several terms that were central to its obviousness arguments, arguing they reflect the ordinary meaning to a POSITA.

  • "layer of conversational protocol": Proposed as "a set of rules and standards governing the semantics of messages between agents." This construction was used to argue that FIPA97’s system of performatives and parameters, which define the meaning and purpose of a message, constitutes the claimed layer.
  • "content layer": Proposed as "a set of rules and standards governing the content embedded within a message." This allowed Petitioner to map FIPA97’s rules for expressing goals, triggers, and data objects to the claimed content layer.
  • "wherein the parameter lists further refine the one or more events": Proposed as "a list of parameters associated with an event can refine the event by affecting the meaning of the event." This construction was critical, as it was added during prosecution to overcome prior art. Petitioner argued that parameters in FIPA97, such as a :receiver parameter with multiple agent names, change the meaning of an "inform" performative from a unicast to a multicast, thereby "refining" the event.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 15, 17-25, 29, 34, 38, and 40-44 of the ’115 patent as unpatentable.