PTAB

IPR2024-01388

Tableau Software LLC v. iCharts LLC

Key Events

Petition

petition

Title: System and Method for Creating Interactive Charts
Brief Description: The ’595 patent relates to systems and methods for generating an interactive chart via a user interface on a first website and transmitting the chart for display and interaction on a second website, without also generating the first website's user interface.

Prior Art Relied Upon: Rostoker (Application # 2008/0127052) and Clark (Application # 2006/0112123).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Rostoker disclosed a system for creating chart-based applications within a modeling environment on a "first website" (a content provider) and included a "Publish" function to generate interactive charts (e.g., as Flash objects) for deployment. Petitioner asserted that Clark supplied the motivation and teaching for transmitting these interactive charts to a separate "second website," such as an internal enterprise portal, which Rostoker did not explicitly describe.
- Motivation to Combine: A POSITA would combine Clark's well-known techniques for publishing charts to an enterprise intranet with Rostoker's chart generation system. This combination would serve the predictable and common business need of making custom-built analytics applications available for internal company use, a goal consistent with both references' focus on business data visualization.
- Expectation of Success: A POSITA would have a reasonable expectation of success in this combination because both references teach publishing content as executable web objects (e.g., Flash), and Rostoker already included a "Publish" and "Deploy" function, making the integration of Clark's publishing target a straightforward modification.

Prior Art Relied Upon: QlikView Reference Manual v8.50 (June 2008) and QlikView Server Reference Manual v8.50 (June 2008) (collectively, "QlikView Manuals").
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended the QlikView Manuals described a single, well-known commercial system that met all limitations of the challenged claims. The system used a Chart Wizard on a first website to generate interactive charts, stored chart templates, and then used an "Objects Client Page Generator" to publish these charts as self-contained web pages (using AJAX or Java Objects). These pages were transmitted via a network interface for display on a second website (e.g., an AJAX client at a different URL), where they remained interactive without executing the first website's generation UI.
- Motivation to Combine: This ground primarily relies on a single, integrated prior art system. Petitioner argued a POSITA would inherently combine the teachings of the two manuals because they describe different components of the same product suite (QlikView v8.50), were published together, and explicitly cross-reference one another.
- Expectation of Success: The expectation of success was high, as the manuals simply document the functionality of an existing, operational, and commercially successful software product.

Prior Art Relied Upon: QlikView Manuals and Couckuyt (Patent 6,906,717).
Core Argument for this Ground:
- Prior Art Mapping: This ground specifically addressed claims requiring a user interface with distinct data and chart panes, where a user drags data from the data pane to the chart pane to generate the chart. While the QlikView Manuals disclosed the underlying system, its chart creation process relied on navigating menus and dialog boxes. Petitioner argued Couckuyt taught the claimed drag-and-drop interface for populating charts, which was a known and more intuitive alternative.
- Motivation to Combine: A POSITA would have been motivated to replace QlikView's menu-driven data selection with Couckuyt's more intuitive drag-and-drop functionality. This would improve the user experience, a key goal in UI design, by allowing users to more easily and efficiently map data fields to chart elements. This was a known design choice to solve the problem of cumbersome data selection.
- Expectation of Success: A POSITA would expect success because implementing pane-based layouts and drag-and-drop functionality were fundamental and well-understood UI design techniques at the time.
Additional Grounds: Petitioner asserted additional obviousness challenges based on Rostoker alone and in further combinations with Jou (to add specific interactive features like drill-down) and Couckuyt (to add the drag-and-drop UI to Rostoker).

Priority Date: Petitioner contended the ’595 patent is not entitled to its earliest provisional filing date (July 2, 2008) and is limited to a priority date no earlier than February 17, 2009. Petitioner argued that key claim limitations, including transmitting the chart to a second website "without the execution of the instructions...to generate the user interface of the first website," constituted new matter added in a later continuation-in-part application. This later priority date makes prior art like the QlikView Manuals (published July 2008) available under 35 U.S.C. §102(a).

Petitioner argued against discretionary denial under 35 U.S.C. §325(d), asserting that the primary prior art references (Rostoker and the QlikView Manuals) are new, non-cumulative art that was not considered during prosecution. Petitioner also made a Sotera stipulation, committing that if the IPR is instituted, it will not raise in a parallel district court litigation any grounds that were raised or reasonably could have been raised in the petition.

Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’595 patent as unpatentable.