Case 1:18-cv-00318-RGA-SRF Document 1 Filed 02/26/18 Page 1 of 135 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
`IPA TECHNOLOGIES INC.,
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` Plaintiff,
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`v.
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`GOOGLE LLC,
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` Defendant.
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`
`
`
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`C.A. No. _________________
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`JURY TRIAL DEMANDED
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`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff IPA Technologies Inc. (“IPA”) as and for its complaint against Google
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`LLC (“Google” or “Defendant”) alleges as follows:
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`PARTIES
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`1.
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`IPA is a Delaware corporation with a principal place of business at 600
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`Anton Blvd., Suite 1350, Costa Mesa, California 92626.
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`2.
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`On information and belief, Defendant Google LLC is a Delaware limited
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`liability company with a principal place of business at 1600 Amphitheatre Parkway,
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`Mountain View, California. Google may be served with process through its registered
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`agent, the Corporation Service Company, 251 Little Falls Drive, Wilmington, Delaware
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`19808.
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`JURISDICTION AND VENUE
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`3.
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`This action arises under the patent laws of the United States, Title 35 of
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`the United States Code. Accordingly, this Court has subject matter jurisdiction under 28
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`U.S.C. §§ 1331 and 1338(a).
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`

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`4.
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`This Court has specific and general personal jurisdiction over Defendant
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`pursuant to due process and/or the Delaware Long Arm Statute, due to Defendant having
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`availed itself of the rights and benefits of Delaware by incorporating under Delaware law
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`and due to its substantial business in this forum, including: (i) at least a portion of the
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`infringement alleged herein; and (ii) regularly doing or soliciting business, engaging in
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`other persistent courses of conduct, and/or deriving substantial revenue from goods and
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`services provided to individuals in Delaware and in this Judicial District.
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`5.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 (b)-(c) and
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`1400(b) because Defendant is resident in this District as it is incorporated in Delaware.
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`BACKGROUND
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`6.
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`SRI International, Inc. (“SRI”), the original owner of the patents-in-suit, is
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`an independent, not-for-profit research institute that conducts client-supported research
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`and development for government agencies, commercial businesses, foundations, and
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`other organizations.
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`7.
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`SRI employs about 2,100 people worldwide, including scientists,
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`engineers, technologists, policy researchers, and corporate and support staff. SRI works
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`with clients to take the most advanced R&D from the laboratory to the marketplace. SRI
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`collaborates across technical and scientific disciplines to generate real innovation and
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`create value by inventing solutions that solve challenging problems and looks ahead to
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`the needs of the future. For more than 70 years, SRI has led the discovery and design of
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`ground-breaking products, technologies, and industries—from the computer mouse and
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`intelligent personal assistants to robotic surgery, medical ultrasound, cancer treatments,
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`and more. The revenue generated by SRI’s R&D projects, commercialization activities,
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`and marketplace solutions is reinvested in SRI capabilities, facilities, and staff to advance
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`its mission.
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`8.
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`Among its many areas of research, SRI has engaged in fundamental
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`research and development related to intelligent personal assistants and speech-based
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`navigation of electronic data sources.
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`9.
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`SRI’s innovative work on personal digital assistants was a key area of
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`development in one of the world’s largest artificial intelligence projects, the Cognitive
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`Assistant that Learns and Organizes (“CALO”). The vision for the SRI-led CALO
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`project, which was funded by the U.S. Defense Advanced Research Projects Agency
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`(“DARPA”), was to create groundbreaking software that could revolutionize how
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`computers support decision-makers.
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`10.
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`SRI’s work on personal digital assistants and speech-based navigation of
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`electronic data sources, which started before the launch of the CALO project, developed
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`further as part of the project. SRI’s engineers were awarded numerous patents on their
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`groundbreaking personal digital assistant and speech-based navigation inventions.
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`11.
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`To bring the personal digital assistant and speech-based navigation
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`technology to the marketplace, SRI formed the spin-off company Siri, Inc. in 2007, and
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`granted it a non-exclusive license to the patent portfolio. The technology was
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`demonstrated as an iPhone app at technology conferences and later released as an iPhone
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`3GS app in February 2010. In April 2010, Apple Inc. acquired Siri, Inc. In 2011, the Siri
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`personal digital assistant was released as an integrated feature of the iPhone 4S.
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`3
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`12.
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`Intelligent personal assistants and speech-based navigation of electronic
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`data sources have continued to be implemented as effective and user-friendly solutions
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`for interacting with electronic devices.
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`13.
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`On May 6, 2016, IPA acquired the SRI patent portfolio at issue here. IPA
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`is a wholly-owned subsidiary of WiLAN, a leading technology innovation and licensing
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`business actively engaged in research, development, and licensing of new technologies.
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`INVENTOR BACKGROUNDS
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`14.
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`Co-inventor Adam Cheyer is today a recognized thought leader in the field
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`of artificial intelligence. After obtaining his computer science degree from Brandeis
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`University and his MS in Computer Science and Artificial intelligence (“AI”), Mr.
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`Cheyer served as a researcher in Artificial Intelligence at SRI International. He authored
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`more than 60 publications and 26 issued patents. He was Chief Architect of CALO, the
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`largest AI project in US history. Previously, he was co-founder and VP Engineering of
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`Siri, a mobile phone virtual personal assistant. As a startup, Siri won the Innovative Web
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`Technologies award at SXSW, and was chosen as a Top Ten Emerging Technology by
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`MIT’s Technology Review before Apple purchased Siri in 2010. He is currently co-
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`founder and VP Engineering of Viv Labs, whose goal is to simplify the world by
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`providing an intelligent interface to everything. Viv Labs is now a wholly-owned
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`subsidiary of Samsung.
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`15.
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`Co-inventor Dr. Luc Julia is named one of the top 100 most influential
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`French developers in the digital world. After receiving his Ph.D. in Multimodal Human-
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`Computer Interfaces from the Ecole Nationale Superieure de Telecommunications in
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`Paris, France, Dr. Julia worked at SRI, where he studied agent architectures, co-founded
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`4
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`Nuance Communications (a world leader in speech recognition), and served as co-
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`founder and director of the Computer Human Interactive Center (CHIC!). He was also
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`Chief Technologist at Hewlett-Packard Company, and Director of Siri at Apple, Inc. He
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`now serves as VP of Innovation at Samsung Electronics’ Strategy and Innovation Center.
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`16.
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`Co-inventor Christine Halverson obtained her MS and Ph.D. in Cognitive
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`Science while working at NASA’s Ames Research Center building next-generation air
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`traffic control software. She worked for SRI as an Interim Program Director of SRI’s
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`CHIC! Most recently she has served at IBM as a researcher at the Thomas J. Watson
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`Research Center for a total of 16 years in the areas of human computer interaction, and
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`the PERCS (Productive Easy-to-Use Reliable Computing System) program, which was
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`part of a DARPA challenge in the High Performance Computing System (HPCS)
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`mandate to develop a peta-scale computer.
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`17.
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`Co-inventor Dimitris Voutsas has a Masters in Computer Science and
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`worked as a Research & Development Engineer at SRI’s CHIC! For the last twelve years
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`he has served at Microsoft as a Project Manager for Windows and Windows Phone, and
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`currently serves as Senior Program Manager for Microsoft’s Bing.
`
`18.
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`Co-inventor David L. Martin worked as a Senior Computer Scientist at the
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`Artificial Intelligence Center of SRI International for over 16 years, and worked as the
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`Senior Manager for Applications Engineering at Siri Inc. and later as an Engineering
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`Manager at Apple Inc. upon Apple’s acquisition of Siri. Since August 2013, he has
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`served as the Senior Research Scientist at Nuance Communications, focusing on artificial
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`intelligence research.
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`PATENT PROSECUTION AND EXAMINATION
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`19.
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`Examiners at the United States Patent and Trademark Office (“USPTO”)
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`review patent applications to determine whether a claimed invention should be granted a
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`patent. In general, the most important task of a patent examiner is to review the technical
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`information disclosed in a patent application and to compare it to the state of the art. This
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`involves reading and understanding a patent application, and then searching the prior art
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`to determine what technological contribution the application teaches the public. A patent
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`is a reward for informing the public about specific technical details of a new invention.
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`The work of a patent examiner includes searching prior patents, scientific literature
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`databases, and other resources for prior art. Then, an examiner reviews the claims of the
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`patent application substantively to determine whether each complies with the legal
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`requirements for granting of a patent. A claimed invention must meet patentability
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`requirements including statutory subject matter, novelty, inventive step or non-
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`obviousness, industrial application (or utility) and sufficiency of disclosure, and
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`examiners must apply federal laws (Title 35 of the United States Code), rules, judicial
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`precedents, and guidance from agency administrators.
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`20.
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`To have signatory authority (either partial or full), Examiners must pass a
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`test equivalent to the Patent Bar. All examiners must have a college degree in engineering
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`or science. Examiners are assigned to “Art Units,” typically groups of 8-15 Examiners in
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`the same area of technology. Thus, by way of required background and work experience,
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`Examiners have special knowledge and skill concerning the technologies examined by
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`them and in their particular Art Unit.
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`21.
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`The basic steps of the examination consist of:
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`• reviewing patent applications to determine if they comply with basic format,
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`rules and legal requirements;
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`• determining the scope of the invention claimed by the inventor;
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`• searching for relevant technologies to compare similar prior inventions with the
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`invention claimed in the patent application; and
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` • communicating findings as to the patentability of an applicant's invention via a
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`written action to inventors/patent practitioners.
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`22.
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`Communication of findings as to patentability are done by way of one or
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`more Office Actions in which the Examiner accepts or rejects proposed claims filed by
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`the applicant(s) and provides reasons for rejections. The applicant(s) are then permitted to
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`file a Response to Office Action, in which claims may be amended to address issues
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`raised by the Examiner, or the applicant states reasons why the Examiner’s findings are
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`incorrect. If an applicant disagrees with a Final Rejection by an Examiner, the applicant
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`may file an appeal with the Patent Trial and Appeal Board (“PTAB”). If, after this
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`process, the USTPO determines that the application meets all requirements, a patent is
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`duly allowed, and after an issue fee is paid, the patent is issued.
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`23.
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`A patent duly allowed and issued by the USTPO is presumptively valid
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`and becomes the property of the inventor(s) or assignee(s).
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`24.
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`A “Continuation Application” is one where, typically after allowance but
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`in any event prior to issuance, the inventor applies for a second, related patent. A
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`Continuation employs substantially the same invention disclosure as the previous,
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`allowed application, but seeks new or different claims.
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`ASSERTED PATENTS
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`U.S. Patent No. 6,851,115
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`IPA is the owner by assignment of U.S. Patent No. 6,851,115 (the “’115
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`25.
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`Patent”). The ’115 Patent is entitled “Software-based Architecture for Communication
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`and Cooperation Among Distributed Electronic Agents.” The ’115 Patent issued on
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`February 1, 2005. A true and correct copy of the ’115 Patent is attached as Exhibit A.
`
`26.
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`The ’115 Patent “is generally related to distributed computing
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`environments and the completion of tasks within such environments . . . [and in
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`particular] teaches a variety of software-based architectures for communication and
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`cooperation among distributed electronic agents.” ’115 Patent at Col. 1, lines 25–29
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`(hereinafter 1:25–29).
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`27.
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`The claimed inventions in the ’115 Patent are directed to new and
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`improved computer functionality and technological processes that address problems
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`rooted in and arising from computer technology.
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`28. When initially filed, the applicants submitted their patent application and
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`patent specification with an appendix containing five source files, cumulatively spanning
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`more than 130 pages of source code.
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`29.
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`The background section of the ’115 Patent specifies the need for an
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`improved and intuitive computer-user interface:
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`More than ever before, the increasing complexity of systems, the development of
`new technologies, and the availability of multimedia material and environments
`are creating a demand for more accessible and intuitive user interfaces.
`Autonomous, distributed, multi-component systems providing sophisticated
`services will no longer lend themselves to the familiar “direct manipulation”
`model of interaction, in which an individual user masters a fixed selection of
`commands provided by a single application. Ubiquitous computing, in networked
`environments, has brought about a situation in which the typical user of many
`software services is likely to be a non-expert, who may access a given service
`infrequently or only a few times.
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`’115 Patent at 2:21-33.
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`30.
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`An overview of the inventions of the ’115 Patent emphasize the improved
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`functioning of the underlying computer’s software architecture:
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`A first embodiment of the present invention discloses a highly flexible, software-
`based architecture for constructing distributed systems. The architecture supports
`cooperative task completion by flexible, dynamic configurations of autonomous
`electronic agents. Communication and cooperation between agents are brokered
`by one or more facilitators, which are responsible for matching requests, from
`users and agents, with descriptions of the capabilities of other agents. It is not
`generally required that a user or agent know the identities, locations, or number of
`other agents involved in satisfying a request, and relatively minimal effort is
`involved in incorporating new agents and “wrapping” legacy applications.
`Extreme flexibility is achieved through an architecture organized around the
`declaration of capabilities by service-providing agents, the construction of
`arbitrarily complex goals by users and service-requesting agents, and the role of
`facilitators in delegating and coordinating the satisfaction of these goals, subject
`to advice and constraints that may accompany them.
`
`
`’115 Patent at 4:58-5:8.
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`31.
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`The fundamental technological nature of the improvements to computer
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`functionality from the inventive software architecture and methods improve the flexibility
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`and expandability of the underlying system as whole is described one way as follows:
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`As new agents connect to the facilitator, registering capability specifications and
`natural language vocabulary, what the user can say and do dynamically changes;
`in other words, the ICL is dynamically expandable. For example, adding a
`calendar agent to the system in the previous example and registering its
`capabilities enables users to ask natural language questions about their “schedule”
`without any need to revise code for the facilitator, the natural language agents, or
`any other client agents. In addition, the interpretation and execution of a task is a
`distributed process, with no single agent defining the set of possible inputs to the
`system. Further, a single request can produce cooperation and flexible
`communication among many agents, written in different programming languages
`and spread across multiple machines.
`
`
`’115 Patent at 8:41-55.
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`32.
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`One of most important technical improvements to the underlying
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`computer functionality is the invention’s ability to process compound or complex goals,
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`which is a significant improvement over even SRI’s own earlier Open Agent Architecture
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`technology:
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`Complex Goal Expressions
`
` A
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` powerful feature provided by preferred embodiments of the present invention is
`the ability of a client agent (or a user) to submit compound goals of an arbitrarily
`complex nature to a facilitator. A compound goal is a single goal expression that
`specifies multiple sub-goals to be performed. In speaking of a “complex goal
`expression” we mean that a single goal expression that expresses multiple sub-
`goals can potentially include more than one type of logical connector (e.g., AND,
`OR, NOT), and/or more than one level of logical nesting (e.g., use of
`parentheses), or the substantive equivalent. By way of further clarification, we
`note that when speaking of an “arbitrarily complex goal expression” we mean that
`goals are expressed in a language or syntax that allows expression of such
`complex goals when appropriate or when desired, not that every goal itself is
`necessarily complex.
`
`
`’115 Patent at 14:43-59; Compare with 4:34-55.
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`33.
`
`The ’115 Patent contains six independent claims and 89 total claims,
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`covering various methods, systems, and computer programs. Claim 61 is a facilitator
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`agent claim:
`
`61. A facilitator agent arranged to coordinate cooperative task completion within
`a distributed computing environment having a plurality of autonomous service-
`providing electronic agents, the facilitator agent comprising:
`
`an agent registry that declares capabilities of service-providing electronic agents
`currently active within the distributed computing environment; and
`a facilitating engine operable to parse a service requesting order to interpret a
`compound goal set forth therein, the compound goal including both local and
`global constraints and control parameters, the service request formed according to
`an Interagent Communication Language (ICL), wherein the ICL includes:
`
` a
`
` layer of conversational protocol defined by event types and parameter lists
`associated with one or more of the events, wherein the parameter lists further
`refine the one or more events; and
`
` a
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` content layer comprising one or more of goals, triggers and data elements
`associated with the events; and
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`the facilitating engine further operable to construct a goal satisfaction plan by
`using reasoning that includes one or more of domain-independent coordination
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`strategies, domain-specific reasoning, and application-specific reasoning
`comprising rules and learning algorithms.
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`34.
`
`The above-disclosed claim limitations from the ’115 Patent comprise
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`various elements, including, e.g., a facilitator agent that coordinates task completion
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`within a distributed computing environment with autonomous service-providing
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`electronic agents, where the facilitator agent includes (i) an agent registry that declares
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`capabilities of service-providing electronic agents and (ii) an engine to parse a service
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`requesting order to interpret a compound goal, including both local and global constraints
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`and control parameters, the service request formed according to an Interagent
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`Communication Language (ICL), a layer of conversational protocol defined by event
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`types and parameter lists associated with one or more of the events, wherein the
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`parameter lists further refine the one or more events; and a content layer comprising one
`
`or more of goals, triggers and data elements associated with the events; and the
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`facilitating engine further operable to construct a goal satisfaction plan by using
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`reasoning that includes one or more of domain-independent coordination strategies,
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`domain-specific reasoning, and application-specific reasoning comprising rules and
`
`learning algorithms. This claim, as a whole, provides significant benefits and
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`improvements discussed previously that directly impact the capacity and functionality of
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`the underlying computer software architecture, such as unprecedented ease to expand the
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`agent-based system with increased functionality without any need to revise code for the
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`facilitator, the natural language agents, or any other client agents, as well as a greater
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`degree of freedom for users to use, and for the claimed system to accept and process an
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`expanded set of more complex and compound requests and inquiries, relative to the prior
`
`art.
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`35.
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`The above-disclosed and claimed facilitator agent in a distributed
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`computing environment with service-providing electronic agents additionally constitutes
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`an unconventional technical solution (for example, a facilitator agent using a specialized
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`interagent communication language with a unique (i) conversation protocol layer defined
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`by event types and parameter lists associated with one or more of the events, wherein the
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`parameter lists further refine the one or more events; and (ii) content layers with goals,
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`triggers, and data elements associated with the events) to address a technological problem
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`rooted in computer technology of coordinating and completing tasks using service-
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`providing electronic agents in a distributed computer environment.
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`Prosecution and Examination of the ’115 Patent
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`The examination of the ’115 Patent required over six years, from the date
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`36.
`
`of the filing of the patent application on January 5, 1999, through the issue date of
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`February 1, 2005.
`
`37.
`
`Three Patent Examiners were involved in examining the application that
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`matured into the ’115 Patent, namely, Examiner Lewis A. Bullock, Jr., and Supervisory
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`Examiners St. John Courtenay III and John Follansbee.
`
`38.
`
`Although the publicly available prosecution history of the ’115 Patent
`
`does not contain a complete summary of various patent examiner searches, it indicates
`
`that Examiner Bullock conducted prior art and/or other searches using at least the patent
`
`examiner systems Web-based Examiner Search Tool (“WEST”) and Examiner
`
`Automated Search Tool (“EAST”), and performed searches on at least July 10, 2002;
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`July 20, 2003; November 20, 2003; August 31, 2004; and September 3, 2004. The Patent
`
`Examiners formally cited at least 19 separate references during the prosecution of the
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`’115 Patent.
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`39.
`
`Between the prior art references located by and cited by the Patent
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`Examiners, and the references submitted by the applicants and considered by the Patent
`
`Examiners during the prosecution of the ’115 Patent, at least 12 patent references and 22
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`non-patent references were formally considered by the Patent Examiners, as indicated on
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`the front two pages of the issued ’115 Patent.
`
`40.
`
`On information and belief, it is the practice of the USPTO not to cite
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`excessive cumulative art, in other words, in this instance, the art cited by the Patent
`
`Examiners is representative of considerable other art located by the USPTO and not cited.
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`Further on information and belief, it is the practice of the USPTO to discuss in its Office
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`Actions those references of which the Patent Examiners are aware that most closely
`
`resemble the claimed inventions.
`
`41.
`
`On September 10, 2004, the USPTO issued a Notice of Allowance as to
`
`all of claims 1-89 presently in the ’115 Patent.
`
`42.
`
`The issued claims from the ’115 Patent are patentably distinct from the at
`
`least 34 references identified and/or discussed during prosecution. That is, each of the 89
`
`claims, as a whole—which include, e.g., electronic agents in a distributed environment
`
`that use an inter-agent language that includes (i) a layer of conversational protocol
`
`defined by event types and parameter lists associated with one or more of the events,
`
`wherein the parameter lists further refine the one or more events, and (ii) a content layer
`
`comprising one or more of goals, triggers and data elements associated with the events,
`
`and/or constructing a goal satisfaction plan that includes using reasoning that includes
`
`one or more of domain-independent coordination strategies, domain-specific reasoning,
`
`and application-specific reasoning comprising rules and learning algorithms, and/or the
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`inter-agent language supporting compound goal expressions such that goals within a
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`single request may be coupled by one or more operators comprising a conditional
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`execution operator, and parallel disjunctive operation that indicates disjunct goals are to
`
`be performed by different agents —were found to be patentably distinct from at least the
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`34 formally identified references.
`
`43.
`
`The references cited during the examination of the ’115 Patent all
`
`represent patentably distinct and in some instances prior art means or methods to navigate
`
`electronic data sources. By allowing the claims of the ’115 Patent, each of the claims in
`
`the ’115 Patent, as a whole was shown to be inventive, novel, and innovative over at least
`
`the 34 formally identified references.
`
`44.
`
`As each claim as a whole from the ’115 Patent is inventive, novel, and
`
`innovative as compared to several specific patents and other publications, each claim as a
`
`whole, constitutes more than the application of well-understood, routine, and
`
`conventional activities.
`
`45.
`
`As of February 19, 2018, the ’115 Patent has been cited as pertinent prior
`
`art by a USPTO examiner or an applicant during the prosecution of at least 266 issued
`
`patents and published applications—including during the prosecution of patent
`
`applications filed by leading technology companies such as IBM, Toshiba, Microsoft,
`
`Apple, Hewlett-Packard, Nuance Communications, and even Google itself. Out of the at
`
`least 266 patent applications in which the ’115 Patent was cited as pertinent prior art
`
`during prosecution, the USPTO has issued more than 169 patents.
`
`46.
`
`The 266 forward citations to the ’115 Patent—and at least 169 patents that
`
`have issued despite identification of the ’115 Patent during their prosecution—reveal that
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`the ’115 Patent and its claimed inventions are directed to specific methods, systems, and
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`programs for an improved software-based architecture for distributed electronic agents to
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`communicate and cooperate, rather than merely disclosing an aspiration or result of that
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`technology that would preempt the use of, or innovations in software-based architectures
`
`for distributed electronic agent communication and cooperation.
`
`47.
`
`The ’115 patent claims priority to January 5, 1999. The technology
`
`disclosed and claimed in the ’115 Patent was not then well-understood, routine or
`
`conventional. To the contrary, the technology claimed in the ’115 Patent was well ahead
`
`of the state of the art at the time of the invention. For example, every Office Action
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`rejection during the entire prosecution of the application that issued as the ’115 patent
`
`was entirely or partially based on publications where one or more inventors was an author
`
`or co-author of the reference.
`
`U.S. Patent No. 7,069,560
`
`IPA is the owner by assignment of U.S. Patent No. 7,069,560 (the “’560
`
`48.
`
`Patent”). The ’560 Patent is entitled “Highly Scalable Software-Based Architecture for
`
`Communication and Cooperation Among Distributed Electronic Agents.” The ’560
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`Patent issued on June 27, 2006. A true and correct copy of the ’560 Patent is attached
`
`hereto as Exhibit B.
`
`49.
`
`The ’560 Patent “is generally related to distributed computing
`
`environments and the completion of tasks within such environments . . . [and in
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`particular] teaches a variety of software-based architectures for communication and
`
`cooperation among distributed electronic agents.” ’560 Patent at Col. 1, lines 25–29
`
`(hereinafter 1:25–29).
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`Case 1:18-cv-00318-RGA-SRF Document 1 Filed 02/26/18 Page 16 of 135 PageID #: 16
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`50.
`
`The claimed inventions in the ’560 Patent are directed to new computer
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`functionality and improvements to technological processes that address problems rooted
`
`in and arising from computer technology.
`
`51.
`
`The ’560 Patent, at 1:5-12, incorporates by reference and identifies as a
`
`related application U.S. Patent Application 09/225,198, filed January 5, 1999 (the parent
`
`application that issued as the ’115 Patent).
`
`52.
`
`The ’560 Patent is a continuation of the ’115 Patent discussed immediately
`
`above. The specifications of the ’115 and ’560 Patents are therefore substantially
`
`identical, and paragraphs 27-32 above regarding the specification of the ’115 Patent are
`
`incorporated by reference as if fully restated here in this section for the ’560 Patent.
`
`53.
`
`The ’560 Patent contains seven independent claims and 55 total claims,
`
`covering various methods, systems, and computer programs. Claim 52 states:
`
`52. A computer implemented process for providing coordinated task completion
`within a distributed computing environment, the distributed computing
`environment including a plurality of autonomous electronic agents, the computer
`implemented method comprising the steps of:
`
`providing at least one agent registry including capabilities of service providing
`electronic agents;
`
`interpreting a service request in the form of a base goal, the service request being
`in a interagent communication language (ICL), the ICL including a layer of
`conversational protocol defined by event types and parameter lists associated with
`one or more of the events, wherein the parameter lists further refine the one or
`more events;
`
`determining a plurality of sub goals necessary to accomplish the base goal;
`selecting from said registry at least one service providing agent capable of
`completing said sub goals;
`delegating at least one sub goal as a peer to peer service request directly from a
`service requesting agent to a service providing agent; and
`
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`Case 1:18-cv-00318-RGA-SRF Document 1 Filed 02/26/18 Page 17 of 135 PageID #: 17
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`delegating any remaining sub goals as service request in the interagent
`communication language to the selected agents capable of completing the
`remaining sub-goals.
`
`54.
`
`The above-disclosed method claim from the ’560 Patent includes various
`
`elements or steps, including, e.g., providing at least one agent registry including
`
`capabilities of service providing electronic agents; interpreting a service request in the
`
`form of a base goal, the service request being in a interagent communication language
`
`(ICL), which in turn includes a layer of conversational protocol defined by event types
`
`and parameter lists associated with one or more of the events, wherein the Parameter lists
`
`further refine the one or more events; determining a plurality of sub goals necessary to
`
`accomplish the base goal; selecting from said registry at least one service providing agent
`
`capable of completing said sub goals; delegating at least one sub goal as a peer to peer
`
`service request directly from a service requesting agent to a service providing agent; and
`
`de