Salesforcecom Inc v. Michael Kaufman

1. Case Identification

• Case #: IPR2021-00397
• Patent #: 7,885,981
• Filed: December 31, 2020
• Petitioner(s): Salesforce.com, Inc.
• Patent Owner(s): Michael Philip Kaufman
• Challenged Claims: 1, 2, 4, 5

2. Patent Overview

• Title: System and Method for Generating Automatic User Interface for Arbitrarily Complex or Large Databases
• Brief Description: The ’981 patent discloses a software system for automatically generating a complete user interface for interacting with a relational database. The system is designed to create the interface without requiring custom software programming by scanning the database to determine its structure and rules.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yeager in view of Nadkarni - Claims 1, 2, 4, and 5 are obvious over Yeager in view of Nadkarni.

• Prior Art Relied Upon: Yeager (Patent 5,590,190) and Nadkarni (“WebEAV: Automatic Metadata-driven Generation of Web Interfaces to Entity-Attribute-Value Databases,” a journal article published in July/August 2000).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Yeager, as the primary reference, discloses a system that scans a relational database's data model and automatically generates a dynamic graphical user interface (DGUI) to interact with it. Yeager’s DGUI was alleged to include various display modes for creating, retrieving, updating, and deleting database records, thereby teaching the core limitations of independent claims 1, 4, and 5. Petitioner contended that Nadkarni, which describes a web-oriented framework for automatically generating web-based forms for database interaction, supplements Yeager by teaching elements such as providing an "output stream" from a server, constructing a "client application" using web technologies, and integrating multiple UI functions into a single view. For dependent claim 2, Petitioner asserted that Yeager discloses revealing non-relational constraints (e.g., column width) and Nadkarni teaches robust client-side validation for enforcing such constraints.
  • Motivation to Combine: A POSITA would combine Yeager and Nadkarni because both references address the same problem of automatically generating user interfaces for databases to reduce programming time and effort. Both references describe systems based on a common back-end database technology (Oracle), which would simplify integration. Market pressures to provide better, more adaptable UIs for valuable database systems would have further motivated a POSITA to combine Yeager's DGUI generation with Nadkarni's web-based interface and validation techniques to create a more robust and modern system.
  • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because the combination relies on straightforward and well-understood client-server and database technologies that could be readily implemented by a competent programmer.

Ground 2: Obviousness over Cason in view of Nadkarni - Claims 1, 2, 4, and 5 are obvious over Cason in view of Nadkarni.

• Prior Art Relied Upon: Cason (Patent 6,035,300) and Nadkarni (a 2000 journal article).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Cason discloses the key elements of the challenged claims. Cason describes a client-server system with an "application generator" that reads the data model of a relational database to build a metadata file. This metadata file is then used to automatically construct a client application with a dynamic UI, which streams to the client device for interacting with the database through create, retrieve, update, and delete modes. The combination with Nadkarni was argued to supply any potentially missing details regarding modern, web-based implementation, such as streaming an output stream over a network using standard protocols (e.g., HTTPS) and performing client-side validation to ensure data integrity, as also argued in Ground 1.
  • Motivation to Combine: The motivation to combine Cason and Nadkarni was presented as being substantially similar to that for combining Yeager and Nadkarni. Both Cason and Nadkarni aim to solve the same problem of building interactive UIs for databases without significant programming effort. A POSITA would have been motivated by market forces and the desire for commercial success to enhance Cason's application generator with the web-oriented techniques taught by Nadkarni, thereby improving the usability and accessibility of the generated UI.
  • Expectation of Success: Petitioner contended that a POSITA would have had a high expectation of success in combining Cason and Nadkarni, as the combination involves applying well-known web technologies to a standard client-server database architecture.

4. Key Claim Construction Positions

• Petitioner argued that most of its proposed claim constructions were immaterial to the invalidity analysis. However, it highlighted the term "managing ... said relationships across tables" as a key exception. The petition provided alternative invalidity arguments for this limitation under two potential constructions:
  • The construction from a prior litigation ("avoiding the insertion of inappropriate data in and across tables"), which Petitioner argued was met by prior art teachings of referential integrity constraint enforcement.
  • Petitioner's proposed construction ("adding or removing cross-references between tables, such as foreign key columns or foreign key constraints"), which it argued was met by prior art UIs that allowed users to modify table structures.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under multiple frameworks.
  • §325(d): Petitioner asserted that the petition relies on new art and arguments not previously before the Office. Specifically, Nadkarni was never considered, and while Yeager and Cason were cited on the face of the ’981 patent, they were never substantively relied upon by the Examiner as a basis for rejection.
  • General Plastic Factors: Petitioner contended that it had not previously challenged the patent, was not a co-defendant with the petitioner in prior IPRs (Microsoft), and had no relationship with Microsoft. It argued that it filed the petition promptly after being sued.
  • NHK-Fintiv Factors: Petitioner argued that the factors strongly favor institution. It noted the co-pending district court case was in its infancy, with minimal investment from the court and parties, and discovery not yet meaningfully underway. Petitioner stated its intent to seek a stay if the IPR were instituted. To eliminate any overlap, Petitioner stipulated that if the IPR is instituted, it will not pursue in the district court proceeding any invalidity grounds based on Yeager, Cason, or Nadkarni.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 4, and 5 of the ’981 patent as unpatentable under 35 U.S.C. §103.