PTAB

IPR2019-00813

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 collective task completion among distributed software agents. The system utilizes a common communication protocol, an “Interagent Communication Language” (ICL), which includes a conversational protocol layer for message structure and a content layer for the substance of the communication (e.g., goals, triggers).

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 11, and 48-60 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 discloses the foundational architecture of a multi-agent system for cooperative problem-solving, but lacks a detailed inter-agent communication language. Kiss teaches a system with a "meta-agent" that acts as a facilitator, an agent registry to track capabilities, and the ability to dynamically formulate a "goal satisfaction plan" by breaking down a user query into sub-goals and delegating them to appropriate agents. Petitioner contended that Kiss thus discloses the broad method steps of claim 1, including registering capabilities, receiving and interpreting a goal expression, generating sub-goals, and constructing a plan to delegate those sub-goals.

      Petitioner asserted that FIPA97, a well-known public standard for agent interoperability, supplies the specific features of the claimed “inter-agent language” that Kiss lacks. FIPA97's Agent Communication Language (ACL) is presented as an expandable, platform-independent language meeting the claim limitations. Specifically, FIPA97's ACL discloses a "layer of conversational protocol" defined by communicative acts (event types) and various parameters, and a "content layer" that can embed goals, triggers, and data. Crucially, Petitioner argued that certain FIPA97 parameters (e.g., the :protocol or multi-recipient :receiver parameter) alter the fundamental meaning of a message's performative, thereby satisfying the key claim limitation that the "parameter lists further refine the one or more events"—the same limitation added during prosecution to distinguish over the prior art KQML language.

    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to combine Kiss with FIPA97 for several reasons. A POSITA would recognize that the multi-agent system in Kiss requires a robust, common communication protocol to function effectively. FIPA97 provided a well-known, standardized, and publicly available solution expressly designed to provide interoperability for such systems. Combining the Kiss architecture with the FIPA97 communication standard was merely implementing a known communication protocol within a known type of system to achieve the predictable result of an operable, distributed agent system. The combination represented a choice from a small number of predictable solutions to a known design need.

    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in making the combination. Both the agent system architecture of Kiss and the communication protocols of FIPA97 were well-known, conventional technologies by 1999. Furthermore, other systems had already successfully integrated FIPA-based technology with agent systems, indicating the combination was straightforward and achievable without undue experimentation.

4. Key Claim Construction Positions

  • "a layer of conversational protocol ... wherein the parameter lists further refine the one or more events": Petitioner argued this phrase, added during prosecution to gain allowance, requires that the parameters affect the fundamental meaning of the event, not just modify its context. Petitioner proposed construing "a layer of conversational protocol" as "a set of rules and standards governing the semantics of messages between agents." The "refine" limitation was argued to mean that a parameter, like the solution_limit(N) example in the patent, can change a request from "ask_one" to "ask_all" or "ask_N", thereby altering the core semantic meaning of the request itself. This construction was central to distinguishing FIPA97 from prior art considered by the examiner, which allegedly only had parameters that modified context (e.g., content language) but did not change the meaning of the performative.
  • "goal": Petitioner proposed construing "goal" as "a request for a service," consistent with its use throughout the patent and prosecution history where "goal" and "sub-goal" were equated with "request" and "sub-request."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 11, and 48-60 of the ’115 patent as unpatentable.