Tableau Software LLC v. iCharts LLC

1. Case Identification

• Case #: IPR2024-01389
• Patent #: 8,520,000
• Filed: September 26, 2024
• Petitioner(s): Tableau Software, LLC
• Patent Owner(s): iCharts LLC
• Challenged Claims: 1-4

2. Patent Overview

• Title: Systems and Methods for Generating and Sharing Interactive Charts
• Brief Description: The 8,520,000 patent describes systems for generating interactive data charts in an online portal. A user can select a chart from a first website (e.g., by dragging and dropping it into a folder) and have it automatically displayed in a "chart box," which is a web widget embedded on a second website.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 are obvious over Rostoker in view of Strong.

• Prior Art Relied Upon: Rostoker (Application # 2008/0127052) and Strong (Application # 2006/0101064).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Rostoker disclosed a method for providing composite applications (“xApps”), including various interactive charts, from a central "storefront" or "hub" (the claimed "first website"). Rostoker taught that a user could select a chart component, use a modeling environment to configure it, and then "Publish" the application. This publication process transformed the components into executable representations like Java or Flash code ("web widgets") for display in "chart boxes" on a separate website, such as a business's local intranet (the claimed "second website"). Rostoker further disclosed that a selection could be made by dragging and dropping a component into a "chart box folder" within the modeling environment.
  • Motivation to Combine: Petitioner contended that Rostoker’s system required a user to manually click a "Publish" button to deploy the application after modification. A person of ordinary skill in the art (POSA) would be motivated to automate this step to reduce the burden on developers and ensure users always accessed the latest version. Strong provided a known technique for this, disclosing a system that automatically synchronizes and distributes a data object to all clients immediately upon its modification. A POSA would combine Strong's automatic distribution with Rostoker's application publishing system.
  • Expectation of Success: A POSA would have a reasonable expectation of success, as the combination involved using a known technique (automatic distribution upon modification) to improve a similar system (application publishing). Rostoker’s system was already configured to detect modifications within its modeling environment.

Ground 2: Claims 1-4 are obvious over Rostoker and Strong in view of Jou.

• Prior Art Relied Upon: Rostoker (Application # 2008/0127052), Strong (Application # 2006/0101064), and Jou (Application # 2003/0071814).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground supplemented the Rostoker and Strong combination. To the extent Rostoker’s teachings on chart "interactivity" were considered insufficient, Petitioner asserted that Jou explicitly disclosed the interactive features recited in the 8,520,000 patent. Jou described an interactive system for visualizing business data with features like data filtering, drill-down on chart axes by double-clicking, and zooming.
  • Motivation to Combine: A POSA would be motivated to incorporate Jou’s advanced interactive features into the Rostoker/Strong system to improve its primary function: enabling users to better visualize, parse, and explore large amounts of business data.
  • Expectation of Success: Success would be predictable, as incorporating known interactive features into an existing data visualization framework was a common practice. Rostoker already disclosed creating charts as Flash or Java runtimes, which were known to support the types of interactions taught by Jou.

Ground 3: Claims 1-4 are obvious over Rostoker and Strong in view of Clark.

• Prior Art Relied Upon: Rostoker (Application # 2008/0127052), Strong (Application # 2006/0101064), and Clark (Application # 2006/0112123).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative to Ground 1. If Rostoker’s disclosure of deploying an application to a "local intranet" was not considered to teach displaying a chart on a "second website," Petitioner argued Clark provided this missing element. Clark taught a business data visualization and publishing system that allowed users to publish interactive charts and dashboards to external websites, specifically including "enterprise portals" on a company's intranet.
  • Motivation to Combine: A POSA would combine Clark's publishing techniques with the Rostoker/Strong system to enable a business to internally host and present the business applications created with Rostoker. This aligns with Rostoker’s stated purpose of creating applications for use in a "dedicated enterprise environment."

Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1, 3, and 4 based on the QlikView Manuals (printed publications from 2008) in view of Bales (Application # 2007/0113194). This combination argued that the QlikView system taught creating and embedding interactive charts on a second website, and Bales taught the missing element of using a drag-and-drop operation to dynamically trigger an automatic update on that second website via an AJAX call.

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner argued that the 8,520,000 patent was not entitled to the priority date of its parent applications (filed in 2008). The petition contended that claim limitations central to the invention—specifically, selecting a chart via drag-and-drop into a "chart box folder" for automatic display on a second website—constituted new matter added for the first time in the 2009 application from which the patent issued. Therefore, Petitioner asserted the correct priority date is February 17, 2009, making references like the QlikView Manuals (published July 2008) valid prior art.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was inappropriate. Citing the Advanced Bionics framework, Petitioner asserted that the primary prior art references (Rostoker, QlikView Manuals, etc.) and the specific invalidity arguments were never presented to or considered by the USPTO during prosecution. The art was argued to be non-cumulative because it disclosed key features, like drag-and-drop into a chart folder, that the patent owner had previously argued were missing from the art of record.
• To preempt a potential denial under Fintiv, Petitioner stipulated that if the IPR is instituted, it will not pursue in the parallel district court litigation any ground raised or that reasonably could have been raised in the petition.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-4 of the 8,520,000 patent as unpatentable under 35 U.S.C. §103.