PTAB

IPR2021-01252

Google LLC v. MindbaseHQ LLC

Key Events

Petition

petition

Title: Database Management and Organizational Protocol
Brief Description: The ’680 patent relates to a database management system that organizes information using principles of grammar. The system categorizes data elements into "tangible" elements (representing concrete nouns with physical weight) and "intangible" elements (representing verbs, adjectives, and adverbs with no physical weight).

Prior Art Relied Upon: Conlon (a 1993 publication describing a lexical database).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Conlon discloses or renders obvious every limitation of the challenged claims. Conlon’s lexical database is stored in a fixed medium (an Oracle Relational Database Management System) and contains tables for different parts of speech. Petitioner asserted that Conlon’s classification of nouns as either "concrete" or "abstract" directly corresponds to the ’680 patent’s "tangible" data elements. The remaining parts of speech (verbs, adjectives, adverbs), stored in separate tables, were argued to be the claimed "intangible" data elements, including "effect" (verb) and "descriptive" (adjective/adverb) data elements. Conlon further teaches linking related data, such as noun-verb relationships, which Petitioner mapped to the claimed linking limitations.
- Motivation to Combine: This ground relies on a single reference, with Petitioner arguing that Conlon anticipates or makes obvious the claimed invention without combination.
- Expectation of Success: Petitioner contended that a person of ordinary skill in the art (POSITA) would have readily understood Conlon's explicit teachings and, where necessary, made simple and predictable modifications, such as creating a separate sub-group for concrete nouns, to arrive at the claimed invention.

Prior Art Relied Upon: Conlon, and Miller (a 1991 publication describing the hierarchical semantic organization of the WordNet database).
Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the teachings of Conlon by adding Miller’s disclosure of organizing lexical data in hierarchical structures. Petitioner argued that Miller’s "lexical inheritance system," which organizes nouns in a "tree" with parent-child relationships (e.g., "oak" is a child of "tree"), directly teaches the claim limitations requiring data to be stored in "hierarchal structures of parent-child relationships." Miller’s disclosure of tree and table structures was mapped to dependent claims requiring those specific formats.
- Motivation to Combine: A POSITA building a lexical database as taught by Conlon would combine it with Miller's well-known hierarchical organization to improve the system. Petitioner noted that Conlon itself identifies WordNet (the subject of Miller’s paper) as a "valuable lexical resource," providing a clear reason to integrate Miller’s organizational principles to enhance Conlon’s database with better inferencing capabilities and more efficient data storage.
- Expectation of Success: A POSITA would have a reasonable expectation of success because implementing hierarchical structures was a widely used technique for organizing large databases, and Conlon's data was already structured in a way that lent itself to such organization.

Prior Art Relied Upon: Conlon, Miller, and Beckwith (a publication describing the computer implementation of WordNet, co-authored by Miller and published in the same journal issue).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Beckwith adds the teaching of presenting Miller's hierarchical data structure in the form of an "outline." Beckwith’s tables show words organized with horizontal indentation to represent their level in the hierarchy, which directly maps to the claim limitation requiring that the "hierarchal structure is an outline."
- Motivation to Combine: A POSITA seeking to implement the hierarchical system of Miller would naturally look to Beckwith, which explicitly describes the computer implementation of that very same system. Beckwith’s use of an outline format is an advantageous and logical method for presenting the hierarchical data taught by Miller, making it an obvious addition to the Conlon/Miller combination.
- Expectation of Success: Organizing hierarchical information in an outline format is a conventional and predictable design choice that presents no technical hurdles.
Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 43-46 based on Conlon, Miller, and Fong, which introduced teachings on database normalization to inter-relate heterogeneous databases.

Petitioner argued that the Board should not exercise its discretion to deny institution under either 35 U.S.C. §325(d) or §314(a).
§325(d): Petitioner contended that the asserted prior art (Conlon, Miller, Beckwith, Fong) was not before the examiner during prosecution. The examiner issued only a single Office action based on double patenting and provided no reasons for allowance, meaning the core teachings of the asserted prior art were never considered.
§314(a) (Fintiv): Petitioner argued that the parallel district court litigation was not in an advanced state. At the time of filing, the case had recently been transferred, no answer had been filed, no trial date was set, and discovery had not commenced. Petitioner asserted that multiple Fintiv factors, including the early stage of the litigation and the likelihood of a stay, weighed strongly against discretionary denial.

Petitioner requests institution of inter partes review and cancellation of claims 1-46 of Patent 6,665,680 as unpatentable.