PTAB

IPR2019-00839

Microsoft Corp v. IPA Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Using a Community of Distributed Electronic Agents to Support a Highly Mobile, Ambient Computing Environment
  • Brief Description: The ’128 patent discloses a system of distributed electronic agents that use an inter-agent communication language (ICL) to cooperatively perform tasks in a mobile computing environment. The ICL features distinct layers, including a conversational protocol, to facilitate complex problem-solving among agents.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kiss and FIPA97 - Claims 1, 22, 41, 42, and 44 are obvious over Kiss in view of FIPA97.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155) and FIPA97 (a 1997 Foundation for Intelligent Physical Agents specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kiss disclosed the foundational system of a "knowledge management system" with cooperative, distributed intelligent agents, an agent registry, and a facilitator agent (meta-agent) for coordinating tasks. However, Kiss did not explicitly teach the claimed inter-agent language with a "layer of conversational protocol" where parameter lists "further refine" events. Petitioner asserted that FIPA97, an industry standard for agent communication, supplied these missing elements. FIPA97's Agent Communication Language (ACL) defines message semantics using performatives (event types) and various parameters. Crucially, Petitioner argued that certain FIPA97 parameters, such as the :protocol parameter, alter the fundamental meaning of a performative, thus satisfying the "further refine" limitation added during prosecution to overcome prior art. FIPA97 also expressly taught organizing agents for a mobile computing environment.
    • Motivation to Combine: A POSITA would combine the Kiss system with the FIPA97 standard because Kiss required a common communication protocol, and FIPA97 was a well-known, predictable, and standardized solution designed to promote interoperability in multi-agent systems. Implementing the FIPA97 ACL in the Kiss system was presented as a convenient and efficient way to facilitate the required communication between agents.
    • Expectation of Success: The combination involved conventional technologies, and Petitioner noted that others had already successfully combined FIPA technology with agent systems, indicating a high expectation of success without undue experimentation.

Ground 2: Obviousness over Kiss, FIPA97, and Obradovich - Claims 7-9, 11, 17, 19, 27-29, 31, 37, 39, and 43 are obvious over Kiss and FIPA97 in view of Obradovich.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155), FIPA97, and Obradovich (Patent 6,009,355).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Kiss/FIPA97 combination to address dependent claims reciting specific mobile computer interface features for automotive use. Petitioner contended that Obradovich, which is directed to vehicle control systems, disclosed the claimed interfaces. Obradovich taught a multimodal user interface with a touchscreen and voice commands for controlling vehicle functions like navigation, lights, and a mobile phone, directly mapping to limitations like an "electronic device control panel" (claim 7). For claim 43, which requires a trigger condition based on a "vehicle sensor," Obradovich's disclosure of an anti-theft routine triggered by a sensor detecting the engine is off was cited as meeting the limitation.
    • Motivation to Combine: A POSITA would add Obradovich's multimodal interface to the Kiss/FIPA97 system to extend its mobile computing capabilities into the automotive environment, a logical application area for mobile agents. This combination would predictably yield a system of distributed agents able to control vehicle functions, a known goal for such technology.

Ground 3: Obviousness over Kiss, FIPA97, and Kennedy - Claims 9-12, 27, and 29-32 are obvious over Kiss and FIPA97 in further view of Kennedy.

  • Prior Art Relied Upon: Kiss (Patent 6,484,155), FIPA97, and Kennedy (Patent 6,167,255).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground also leveraged the base Kiss/FIPA97 combination to address dependent claims directed to a "communication center panel" with email, telephony, and voicemail interfaces responsive to voice commands. Petitioner argued that Kennedy disclosed a mobile communication system with a user interface providing these exact functionalities. Kennedy's teachings included using voice commands to navigate menus and speech synthesis to play back emails, directly corresponding to limitations such as an "email interface...responsive to voice command input" (claim 10) and a "voicemail interface responsive to Voice commands" including "decision branching commands" (claim 12), as Kennedy's IVR system allows navigation through menu levels.
    • Motivation to Combine: A POSITA would integrate the communication features from Kennedy into the Kiss/FIPA97 system to enhance the functionality and mobility of its users, as such features were becoming standard on mobile devices like the PDAs described in FIPA97. This was presented as a known technique for improving mobile computing systems.

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 its argument that the claims require more than a simple messaging format.
  • "wherein the parameter lists further refine the one or more events": Petitioner argued this phrase means that a parameter list must be capable of affecting the core semantic meaning of an event (the message). This was positioned as the key feature added during prosecution to overcome prior art (Nwana), where parameters only modified a message (e.g., specifying content language) without altering the meaning of the performative itself. This distinction was critical to Petitioner's assertion that FIPA97's parameters, which can change a request from a standard proposal to an auction proposal, meet this limitation.

5. Relief Requested

  • Petitioner requested institution of inter partes review and cancellation of claims 1, 7-12, 17, 19, 22, 27-32, 37, 39, and 41-44 as unpatentable.