Willow Technologies LLC v. Johnson Controls Technology Co

1. Case Identification

• Case #: IPR2023-00170
• Patent #: 10,515,098
• Filed: November 7, 2022
• Petitioner(s): Willow Technologies, LLC
• Patent Owner(s): Johnson Controls Technology Co
• Challenged Claims: 9, 10, 11, and 18

2. Patent Overview

• Title: Graph Data Structure for Building System and Time Series
• Brief Description: The ’098 patent discloses a building management cloud computing system that uses a graph data structure to manage timeseries data. The system relates a plurality of objects (representing spaces, devices, etc.) via interconnected "smart entities" to organize and access data from a smart building environment.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nagano - Claims 9-11 and 18 are obvious over Nagano.

• Prior Art Relied Upon: Nagano (Application # 2017/0270124).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Nagano, a patent application teaching a knowledge graph for integrating timeseries data in building systems, discloses all limitations of the challenged claims. Independent claims 9 (method) and 18 (system) require a database of interconnected smart entities, which Petitioner mapped to Nagano’s "knowledge graph data" comprising various interconnected data layers (spatial, facility, measurement). Petitioner asserted that Nagano’s system receives raw data from sensors, generates corresponding timeseries (e.g., temperature and humidity data), identifies object entities (like a specific sensor) from identifiers within the timeseries, and stores this timeseries data in corresponding data entities ("MeasurementValue" nodes) within the graph. The relationships between entities, such as a sensor being "measuredBy" a measurement, were argued to be the claimed "relational objects."
  • Motivation to Combine (for §103 grounds): This ground relied primarily on Nagano, but Petitioner argued that to the extent Nagano did not explicitly teach using an identifier within a timeseries to find an object entity, a person of ordinary skill in the art (POSITA) would have found it obvious to do so. Petitioner contended that including identification data within a timeseries structure was a conventional and typical practice in the art, making its application to Nagano's disclosed data structure a simple and obvious design choice.
  • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in applying these conventional data handling techniques to Nagano’s system to achieve a predictable result.

Ground 2: Obviousness over Bornside and Hu - Claims 9-11 and 18 are obvious over Bornside in view of Hu.

• Prior Art Relied Upon: Bornside (WO 2013/050333) and Hu (a 2016 journal article titled "Building performance optimisation: A hybrid architecture for the integration of contextual information and time-series data").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Bornside teaches a building automation system with a hierarchical model of interconnected objects ("view node objects") representing devices and their data, which corresponds to the claimed "database of interconnected smart entities." Bornside’s system receives raw data (e.g., temperature readings from sensors) and uses relational objects ("connects relation," "owns relation") to link entities. However, Bornside does not explicitly detail the management of timeseries data. Petitioner argued that Hu remedies this deficiency by teaching a hybrid architecture that integrates timeseries data into a graph data structure with contextual information, directly addressing how to link timeseries data entities to object entities in a building system. The combination of Bornside’s foundational system with Hu’s timeseries integration method was alleged to teach all limitations of the challenged claims.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Bornside with Hu to improve Bornside’s system by adding a known solution for a known problem. Petitioner argued that handling timeseries data was a ubiquitous need in building management systems, as explained by Hu. A POSITA would have recognized the benefit of incorporating Hu’s specialized timeseries handling techniques into Bornside’s general building automation framework to create a more robust and capable system. This represented a predictable use of prior art elements according to their established functions.
  • Expectation of Success (for §103 grounds): Success was expected because both references operate in the same field of building automation and provide a clear roadmap for integrating their respective teachings, yielding only predictable results.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that no factors justify discretionary denial under Fintiv. The co-pending district court litigation was asserted to be in its infancy, with no trial date set and initial infringement contentions having been served only about one month prior to the IPR filing. Petitioner maintained it acted diligently in filing the petition, and that institution would not be an inefficient use of Board resources.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 9, 10, 11, and 18 of the ’098 patent as unpatentable.