Tableau Software LLC v. iCharts LLC

1. Case Identification

• Case #: IPR2024-01387
• Patent #: 8,271,892
• Filed: September 26, 2024
• Petitioner(s): Tableau Software, LLC
• Patent Owner(s): iCharts LLC
• Challenged Claims: 1-16

2. Patent Overview

• Title: Systems and Methods for Generating Interactive Charts
• Brief Description: The ’892 patent describes systems and methods for generating interactive charts through a user interface and publishing or embedding them as "self-contained and independent" electronic documents that retain interactivity when opened outside the creation environment.

3. Grounds for Unpatentability

Ground 1: Obviousness over Becerra and Couckuyt - Claims 3, 10-11, and 13-16 are obvious over Becerra in view of Couckuyt.

• Prior Art Relied Upon: Becerra (Application # 2003/0169295) and Couckuyt (Patent 6,906,717).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Becerra taught a system for generating interactive control panels, including charts, from spreadsheet data and exporting them as standalone Flash files. However, Becerra did not explicitly disclose an intuitive method for assigning data to different chart aspects. Couckuyt allegedly supplied this missing element by teaching a drag-and-drop user interface (DDUI) that allows a user to drag data fields from a data pane and drop them into designated zones on a chart pane to populate the chart. The combination allegedly taught the limitations of claim 3, including a generation interface with a data pane and a chart pane allowing a user to drag and drop data.
  • Motivation to Combine: A POSITA would combine Couckuyt's well-known DDUI with Becerra's system to improve usability and provide an intuitive and efficient method for assigning data to chart components. Petitioner asserted this would have been a mere design choice to simplify the user workflow for creating charts with multiple data associations.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success, as combining a known UI feature like drag-and-drop into a standard software application was a routine task. Petitioner noted Becerra's disclosure of using the Microsoft Foundation Class (MFC) library, which has built-in support for drag-and-drop functionality.

Ground 2: Obviousness over QlikView Manuals - Claims 1, 2, and 5-9 are obvious over the QlikView Manuals.

• Prior Art Relied Upon: QlikView Reference Manual V8.50 (June 2008) and QlikView Server Reference Manual V8.50 (June 2008) (collectively, "the QlikView Manuals").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended the QlikView Manuals, taken together, disclosed every element of independent claim 1. They described a comprehensive business intelligence system with a data module for loading and storing data, a chart template module for storing chart themes ("templates"), a generation module (the Chart Wizard UI), and a sharing module for publishing interactive charts. The manuals taught publishing charts as interactive webpages or embedding them in Excel documents, which are "self-contained and independent" and retain interactivity (e.g., sorting, data entry) separate from the generation interface.
  • Motivation to Combine (Manuals): A POSITA would have read the two manuals together because they described different components of the same integrated product suite (QlikView 8.50), were intended for use together, and cross-referenced each other.
  • Expectation of Success: Success was expected because the manuals described an existing, functional, and integrated commercial product.

Ground 3: Obviousness over Becerra, Couckuyt, and Keys - Claims 10-11 and 13-16 are obvious over Becerra in view of Couckuyt and Keys.

• Prior Art Relied Upon: Becerra (Application # 2003/0169295), Couckuyt (Patent 6,906,717), and Keys (Application # 2001/0050681).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground built upon the Becerra/Couckuyt combination to further address the limitation in independent claim 10 requiring that "the chart template is stored in a chart template module located on a remote server." Petitioner argued that while Becerra disclosed storing templates locally, Keys explicitly taught a client-server environment where templates for graphical presentations were stored in a central database on a remote server computer.
  • Motivation to Combine: A POSITA would have been motivated to modify the Becerra/Couckuyt system to store chart templates on a remote server, as taught by Keys, to solve the known business problem of maintaining consistency and uniformity across an organization. This approach would allow for centralized updates and ensure all users have access to the same set of approved templates.
  • Expectation of Success: The combination was asserted to be predictable, as using remote servers to store business application assets was a common and well-understood practice in client-server architecture.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including Becerra in view of Moyer (adding a "copy-to-my-account" feature for claim 6); Becerra in view of Jou (adding interactive features like zoom and drill-down for claim 7); and parallel grounds based on the QlikView Manuals combined with Couckuyt, Keys, and Moyer.

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner contended the ’892 patent was not entitled to the filing date of its provisional application (July 2, 2008) because the provisional allegedly lacked written description support under 35 U.S.C. §112 for key limitations, such as publishing a chart as a "self-contained and independent electronic document." Petitioner argued the effective priority date should be the non-provisional filing date of September 5, 2008, which renders the QlikView Manuals (published July 8, 2008) available as prior art.
• "Printed Publication" Status of QlikView Manuals: Petitioner argued the QlikView Manuals qualify as "printed publications" because they were publicly accessible and available for download from the QlikTech company website at least by July 8, 2008, prior to the patent's asserted effective priority date. This argument was supported by declarations and evidence from internet archives.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was inappropriate because the primary references asserted in the petition (Becerra, QlikView Manuals, Keys, Jou, Moyer) were never presented to or considered by the examiner during prosecution. Petitioner asserted the art was not cumulative because it disclosed the very features—specifically, publishing a self-contained and independent interactive chart—that the patentee relied upon to argue for patentability over the art of record.

6. Relief Requested

• Petitioner requests the institution of an inter partes review and the cancellation of claims 1-16 of Patent 8,271,892 as unpatentable.