Filed on behalf of: CoreLogic, Inc.
`By:
`Joseph E. Palys (josephpalys@paulhastings.com)
`
`Naveen Modi (naveenmodi@paulhastings.com)
`
`Daniel Zeilberger (danielzeilberger@paulhastings.com)
`
`Paul Hastings LLP
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`CORELOGIC, INC.
`
`Petitioner
`
`v.
`
`BOUNDARY SOLUTIONS, INC.
`
`Patent Owner
`
`____________________
`
`Case No. IPR2015-00222
`Patent No. 8,065,352
`____________________
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`By:
`Joseph E. Palys (josephpalys@paulhastings.com)
`
`Naveen Modi (naveenmodi@paulhastings.com)
`
`Daniel Zeilberger (danielzeilberger@paulhastings.com)
`
`Paul Hastings LLP
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`CORELOGIC, INC.
`
`Petitioner
`
`v.
`
`BOUNDARY SOLUTIONS, INC.
`
`Patent Owner
`
`____________________
`
`Case No. IPR2015-00222
`Patent No. 8,065,352
`____________________
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`Inter Partes Review of U.S Patent No. 8,065,352
`Case No. IPR2015-00219
`Case No. IPR2015-00222
`
`Inter Partes Review of U.S. Patent No. 7,499,946
`Case No. IPR2015-00226
`
`Inter Partes Review of U.S. Patent No. 7,092,957
`Case No. IPR2015-00228
`
`Oral Hearing: February 11, 2016
`
`1
`
`
`
`Instituted Grounds
`• U.S. Patent No. 8,065,352
`– IPR2015-00219
`− Claims 12-15 and 17-21 are anticipated by Oosterom
`– IPR2015-00222
`− Claims 9, 10, and 12-22 are obvious over Harder and Du
`− Claims 1-8, 11, and 23 are obvious over Harder, Du, and MacDonald
`− Claims 1-23 are obvious over Harder and Longley
`
`• U.S. Patent No. 7,499,946
`– IPR2015-00226
`− Claims 1-10 and 12-21 are obvious over Harder and Longley
`− Claim 11 is obvious over Harder, Longley, and Roy
`− Claims 1-6, 20, and 21 are obvious over Kearney and ARC/INFO
`
`• U.S. Patent No. 7,092,957
`– IPR2015-00228
`− Claims 1-10 and 12-19 are obvious over Harder and Longley
`− Claim 11 is obvious over Harder, Longley, and Roy
`− Claims 1-8 and 16-19 are obvious over Kearney and ARC/INFO
`
`
`
`2
`2
`
`
`
`Challenged Patents
`
`’352 Patent at Fig. 1
`
`Ex. 1001, ’352 Patent at Fig. 1
`
`3
`3
`
`
`
`Challenged Patents
`
`’352 Patent at Fig. 1
`
`’352 Patent at 4:50-64
`
`Ex. 1001, ’352 Patent
`
`4
`4
`
`
`
`Conventional Technologies
`Databases
`Identifiers
`
`Ex. 1034 at 21:2-5
`
`Directories
`
`Ex. 1034 at 22:21-23:2
`
`Indexing
`
`Ex. 1034 at 23:10-17
`Indexing
`
`Ex. 1034 at 24:21-25:1
`
`IPR2015-00219 Reply at 1-2
`
`Ex. 1034 at 26:16-21
`
`5
`5
`
`
`
`Conventional Technologies
`
`’352 Patent at 3:26-53
`
`
`’352 Patent at 3:54-4:4
`
`
`’352 Patent at 4:8-16
`
`
`IPR2015-00222 PO Resp. at 47-48; Ex. 1034 at 29:15-32:17, 32:18-40:22
`
`6
`6
`
`
`
`Instituted Grounds
`(IPR2015-00222)
`U.S. Patent No. 8,065,352
`
`7
`
`
`
`Instituted Grounds: IPR2015-00222
`
`• 35 U.S.C. § 103
`– Claims 9, 10, and 12-22 are obvious over Harder and Du
`– Claims 1-8, 11, and 23 are obvious over Harder, Du, and
`MacDonald
`– Claims 1-23 are obvious over Harder and Longley
`
`
`IPR2015-00222 Institution Decision at 19
`
`8
`8
`
`
`
`’352 Patent Claims
`
`12. A method for retrieving and displaying geographic parcel boundary
`polygon maps comprising:
`receiving, by a server, a request for a parcel boundary polygon map for a
`selected parcel;
`searching, by the server, using a jurisdictional identifier a multi-
`jurisdictional digital parcel map database for the selected parcel
`boundary polygon and the parcel boundary polygons of adjacent and
`surrounding parcels, the database having information about individual
`land parcels normalized to a common spatial data protocol, including
`polygon data used to describe the boundaries of a plurality of
`properties; and,
`transmitting the parcel boundary polygon map data for the selected parcel
`along with the adjacent and surrounding parcels for display, wherein
`the parcel boundary polygon map includes the selected parcel
`polygon along with adjacent and surrounding parcel boundary
`polygons around the selected parcel.
`
`
`Exhibit 1001, ’352 Patent at claim 12
`
`9
`9
`
`
`
`’352 Patent Claims
`
`9. A method for retrieving and displaying geographic parcel boundary polygon, maps
`comprising:
`receiving, by a server, a request for a parcel boundary polygon map for a selected
`parcel;
`retrieving, by the server, a jurisdictional identifier associated with the selected
`parcel from an index of a multi-jurisdictional digital parcel map database,
`searching, by the server using the jurisdictional identifier, a portion of the
`multi-jurisdictional database in which the selected parcel boundary polygon
`and the parcel boundary polygons Of adjacent and surrounding parcels are
`located, the database containing information about individual land parcels
`normalized to a common spatial data protocol, including polygon data used to
`describe the boundaries of a plurality of properties; and,
`transmitting the parcel boundary polygon map data for the selected parcel along
`with the adjacent and surrounding parcels for display, wherein the parcel
`boundary polygon map includes the selected parcel polygon along with
`adjacent and surrounding parcel boundary polygons around the selected
`parcel, with the selected parcel highlighted.
`
`
`Exhibit 1001, ’352 Patent at claim 9
`
`10
`10
`
`
`
`’352 Patent Claims
`
`1. A method for retrieving and displaying geographic parcel boundary polygon maps
`comprising:
`receiving, by a server, a request for a parcel boundary polygon map for a selected
`parcel;
`searching, by the server, using a jurisdictional identifier, a multi-jurisdictional
`digital parcel map database for the selected parcel boundary polygon and the
`boundary polygons of adjacent and surrounding parcels, the database having
`information about individual land parcels normalized to a common spatial
`data protocol, including polygon data used to describe the boundaries of a
`plurality of properties, wherein the multi-jurisdictional digital parcel map
`database includes a plurality of records arranged in separate service area
`directories corresponding to multi-jurisdictional service areas within two or
`more states;
`transmitting the parcel boundary polygon map data for the selected parcel along
`with the adjacent and surrounding parcels to a client computer for display,
`wherein the transmitted parcel boundary polygon map includes the selected
`parcel polygon along with adjacent and surrounding parcel boundary
`polygons around the selected parcel.
`
`Exhibit 1001, ’352 Patent at claim 1
`
`11
`11
`
`
`
`IPR2015-00222
`Claim Constructions
`
`12
`
`
`
`“multi-jurisdictional database”
`
`Board
`collection of data relating to two or
`more jurisdictions (Dec. at 6)
`
`Patent Owner
`a database including multiple
`jurisdictional databases, wherein a
`jurisdictional database is a
`collection of data representing the
`boundaries of parcels from a
`jurisdiction (Resp. at 9)
`
`IPR2015-00222 Reply at 2; IPR2015-00219 Reply at 3-4
`
`13
`13
`
`
`
`“jurisdiction”
`
`Board
`
`Patent Owner
`
`No construction offered (Dec. at 6-7)
`
`No formal construction offered * (Resp. at 8)
`
`IPR2015-00222 Reply at 3-4
`
`14
`14
`
`
`
`“jurisdiction”
`
`Ex. 1034 at 70:17-71:6
`
`Ex. 1034 at 66:19-67:8
`
`IPR2015-00222 Reply at 3-4
`
`15
`15
`
`
`
`“jurisdictional identifier”
`
`Board
`a number or other name, code, or
`description that identifies a
`jurisdiction (Dec. at 7)
`
`Patent Owner
`No formal construction offered*
`(Resp. at 8-25)
`
`IPR2015-00222 Reply at 6-7
`
`16
`16
`
`
`
`“jurisdictional identifier”
`
`IPR2015-00222 Reply at 6-7
`
`17
`17
`
`Ex. 1034 at 72:5-22
`
`
`
`“normalized to a common spatial protocol”
`
`Patent Owner
`Board
`No construction offered (Dec. at 6-7) The individual land parcels polygon
`data has been received from a
`jurisdiction and modified,
`transformed, amended or converted
`by a set of one or more processes
`applied to data and updates from the
`each of the individual jurisdictional
`databases making up the multi-
`jurisdictional database (Resp. at 16-
`17)
`
`IPR2015-00222 Reply at 4-6
`
`18
`18
`
`
`
`“normalized to a common spatial protocol”
`
`Institution Decision at 7
`
`IPR2015-00222 Reply at 4-6
`
`19
`19
`
`
`
`“normalized to a common spatial protocol”
`
`Ex. 1034 at 57:4-10
`
`Ex. 1034 at 58:3-7
`
`Ex. 1034 at 57:11-58:2
`
`IPR2015-00222 Reply at 4-6
`
`20
`20
`
`
`
`“normalized to a common spatial protocol”
`
`IPR2015-00222 Reply at 4-6
`
`21
`21
`
`Ex. 1034 at 59:11-60:7
`
`
`
`“service area directories”
`
`Patent Owner
`Board
`No construction offered (Dec. at 5-7) “service area directories
`corresponding to multi-jurisdictional
`service areas” means “multiple
`directories each containing
`records/files covering a jurisdiction’s
`geographic extent, the jurisdictions
`being within two or more states and
`included in the multi-jurisdictional
`digital parcel map database” (Resp.
`at 22-23)
`
`IPR2015-00222 Reply at 6-7
`
`22
`22
`
`
`
`“portion of the multi-jurisdictional database”
`
`Patent Owner
`Board
`No construction offered (Dec. at 5-7) geographic area within the spatial
`extent of the multi jurisdictional
`database that includes the selected
`parcel and adjacent and surrounding
`parcels (Resp. at 22-23)
`
`IPR2015-00222 Reply at 8
`
`23
`23
`
`
`
`Patent Owner’s Constructions
`
`IPR2015-00222 Reply at 1; IPR2015-00219 Reply at 3
`
`24
`
`
`
`Patent Owner’s Constructions
`
`IPR2015-00222 Reply at 1; IPR2015-00219 Reply at 4
`
`25
`
`
`
`IPR2015-00222
`Harder and Du
`(claims 9, 10, and 12-22 )
`
`26
`
`
`
`Patent Owner: Harder and Du Issues
`
`• Patent Owner argues Harder does not disclose a “multi-
`jurisdictional database” (Resp. at 32-34)
`• Patent Owner argues that Harder does not disclose data
`“normalized to a common data protocol” (Resp. at 35)
`• Patent Owner argues that Du does not disclose a “multi-
`jurisdictional database” and Du’s cell ID is not a
`“jurisdictional identifier” (Resp. at 35-38)
`• Patent Owner argues that Du’s system would be inefficient
`(Resp. at 38-40)
`
`IPR2015-00222 Reply at 8-15; PO Resp. at 32-40
`
`27
`27
`
`
`
`Limitations At Issue
`
`9. A method for retrieving and displaying geographic parcel boundary polygon, maps
`comprising:
`receiving, by a server, a request for a parcel boundary polygon map for a selected
`parcel;
`retrieving, by the server, a jurisdictional identifier associated with the selected
`parcel from an index of a multi-jurisdictional digital parcel map database,
`searching, by the server using the jurisdictional identifier, a portion of the
`multi-jurisdictional database in which the selected parcel boundary polygon
`and the parcel boundary polygons Of adjacent and surrounding parcels are
`located, the database containing information about individual land parcels
`normalized to a common spatial data protocol, including polygon data used to
`describe the boundaries of a plurality of properties; and,
`transmitting the parcel boundary polygon map data for the selected parcel along
`with the adjacent and surrounding parcels for display, wherein the parcel
`boundary polygon map includes the selected parcel polygon along with
`adjacent and surrounding parcel boundary polygons around the selected
`parcel, with the selected parcel highlighted.
`
`
`Exhibit 1001, ’352 Patent at claim 9
`
`28
`28
`
`
`
`Limitations At Issue
`
`12. A method for retrieving and displaying geographic parcel boundary
`polygon maps comprising:
`receiving, by a server, a request for a parcel boundary polygon map for a
`selected parcel;
`searching, by the server, using a jurisdictional identifier a multi-
`jurisdictional digital parcel map database for the selected parcel
`boundary polygon and the parcel boundary polygons of adjacent and
`surrounding parcels, the database having information about individual
`land parcels normalized to a common spatial data protocol, including
`polygon data used to describe the boundaries of a plurality of
`properties; and,
`transmitting the parcel boundary polygon map data for the selected parcel
`along with the adjacent and surrounding parcels for display, wherein
`the parcel boundary polygon map includes the selected parcel
`polygon along with adjacent and surrounding parcel boundary
`polygons around the selected parcel.
`
`
`Exhibit 1001, ’352 Patent at claim 12
`
`29
`29
`
`
`
`Harder
`
`Ex. 1003 at 22
`
`Ex. 1003 at 24
`
`IPR2015-00222 Pet. at 14-16
`
`30
`30
`
`
`
`Du
`
`Ex. 1018 at 6:65-7:1
`
`Ex. 1018 at 7:14-21
`
`IPR2015-00222 Reply at 12-13
`
`Ex. 1018 at Fig. 3
`
`31
`31
`
`
`
`Du
`
`Ex. 1018 at 7:30-37
`
`Ex. 1018 at 8:55-58
`
`Ex. 1018 at 8:50-54
`
`IPR2015-00222 Pet. at 16; Reply at 12-14
`Ex. 1018 at 9:1-5
`
`IPR2015-00222 Pet. at 16; Reply at 12-14
`
`32
`32
`
`
`
`Du
`
`Ex. 1018 at 2:13-26
`
`Ex. 1018 at 9:35-44
`
`IPR2015-00222 Pet. at 16; Reply at 12-14
`
`33
`33
`
`
`
`Patent Owner: Du’s Cell ID
`
`PO Resp. at 35-36
`
`Ex. 1034 at 105:4-22
`
`IPR2015-00222 Reply at 12
`
`34
`34
`
`
`
`Patent Owner: Du’s Cell ID
`
`Ex. 1034 at 106:1-13
`
`IPR2015-00222 Reply at 12
`
`35
`35
`
`
`
`Patent Owner: Du’s Cell ID
`
`Ex. 1034 at 110:12-111:14
`
`IPR2015-00222 Reply at 12, 14
`
`36
`36
`
`
`
`IPR2015-00222
`Harder, Du, and MacDonald
`(claims 1-8, 11, and 23)
`
`37
`
`
`
`Patent Owner: MacDonald Issues
`
`• Patent Owner argues MacDonald does not disclose “service
`area directories” (Resp. at 40-42)
`• Patent Owner argues MacDonald does not disclose
`“combining multiple jurisdictional databases to a common
`spatial data protocol” (Resp. at 42)
`• Patent Owner argues MacDonald does not disclose an “index
`of jurisdictional databases to identify the portion of the
`multijurisdictional database in which the selected parcel is
`located” as claimed in claim 7” (Resp. at 42)
`
`IPR2015-00222 Reply at 15-17; PO Resp. at 40-42
`
`38
`38
`
`
`
`MacDonald
`
`Ex. 1020 at 78
`
`IPR2015-00222 Reply at 15-17
`
`39
`39
`
`
`
`Patent Owner: MacDonald
`
`Ex. 1034 at 120:8-121:13
`
`IPR2015-00222 Reply at 15-17
`
`40
`40
`
`
`
`Patent Owner: MacDonald
`
`Ex. 1034 at 121:14-122:13
`
`IPR2015-00222 Reply at 15-17
`
`41
`41
`
`
`
`IPR2015-00222
`Harder and Longley
`(claims 1-23)
`
`
`42
`
`
`
`Harder and Longley Issues
`
`• Patent Owner argues Harder does not disclose a “multi-
`jurisdictional database” or normalized data (Resp. at 43-45)
`• Patent Owner argues that Longley does not disclose a “multi-
`jurisdictional database” or indexing (Resp. at 45)
`• Patent Owner argues Longley does not disclose “service area
`directories” (Resp. at 51-52)
`• Patent Owner argues Longley does not disclose the limitations
`in claim 7 (Resp. at 52)
`
`PO Resp. at 43-52
`
`43
`43
`
`
`
`Patent Owner: Longley Issues
`
`PO Resp. at 45
`
`PO Resp. at 43-52
`
`PO Resp. at 49-50
`
`44
`44
`
`
`
`Patent Owner: Longley Issues
`
`PO Resp. at 47
`
`IPR2015-00222 PO Resp. at 43-52
`
`45
`45
`
`
`
`Longley
`
`Ex. 1015 at 36
`
`IPR2015-00222 Pet. at 41-46, 49-52; Reply at 17-24
`
`46
`46
`
`
`
`Longley
`
`Ex. 1015 at 226
`
`Ex. 1015 at 226
`
`Ex. 1015 at 237
`
`Ex. 1015 at 228
`
`IPR2015-00222 Pet. at 41-46, 49-52; Reply at 17-24
`
`47
`47
`
`
`
`Longley
`
`Ex. 1015 at 228, 229
`
`IPR2015-00222 Pet. at 41-46, 49-52; Reply at 17-24
`
`48
`48
`
`
`
`Longley
`
`Ex. 1015 at 231
`
`IPR2015-00222 Pet. at 41-46, 49-52; Reply at 17-24
`
`49
`49
`
`
`
`Longley
`
`Ex. 1015 at 237
`
`IPR2015-00222 Reply at 21-22
`
`50
`50
`
`
`
`Longley
`
`Ex. 1015 at 237
`
`Ex. 1015 at 238
`
`IPR2015-00222 Reply at 21-22
`
`51
`51
`
`
`
`Longley
`
`Ex. 1034 at 142:17-21
`
`Ex. 1015 at 73
`
`IPR2015-00222 Reply at 21
`
`52
`52
`
`
`
`Longley
`
`Ex. 1034 at 144:14-16
`
`Ex. 1034 at 144:20-145:4
`
`Ex. 1015 at 296
`
`IPR2015-00222 Reply at 21
`
`53
`53
`
`
`
`Instituted Grounds
`(IPR2015-00226)
`U.S. Patent No. 7,499,946
`
`54
`
`
`
`Instituted Grounds: IPR2015-00226
`
`• 35 U.S.C. § 103
`– Claims 1-10 and 12-21 are obvious over Harder and
`Longley
`– Claim 11 is obvious over Harder, Longley, and Roy
`– Claims 1-6, 20, and 21 are obvious over Kearney and
`ARC/INFO
`
`
`
`IPR2015-00226 Institution Decision at 21
`
`55
`55
`
`
`
`’946 Patent Claims
`
`56
`56
`
`1. An interactive computer implemented method for retrieving geographic parcel boundary
`polygon maps and associated parcel attribute data linked to a non-graphic database, wherein the
`data is acquired electronically, comprising:
`activating a computer terminal;
`a.
`b.
`accessing an applications program for access to the data;
`c.
`accessing a data entry screen and entering a parcel attribute to call up the parcel
`selected;
`d.
`subsequently accessing a multi-state parcel map database comprising multiple
`jurisdictional databases which have been normalized to a common data protocol;
`e.
`searching a jurisdiction look up table associated with the multi-state parcel map
`database, said look up table indexed for identification of the pertinent jurisdictional
`database, whereby a jurisdictional identifier for the selected jurisdiction is located, and the
`identified jurisdictional database thereafter accessed; and,
`f.
`thereafter displaying on screen a parcel boundary polygon map, along with
`surrounding parcel boundary polygons, the default scale of the displayed map selected to fill
`the computer display screen with parcel boundaries within a selected distance around the
`subject parcel, the selected parcel boundary polygon highlighted, defining both the location
`and boundary of the parcel, and associated attribute data for the highlighted parcel
`displayed.
`
`
`
`
`
`57
`57
`
`’946 Patent Claims
`
`20. An interactive computer implemented method for retrieving geographic parcel boundary
`polygon maps and associated parcel attribute data linked to a non-graphic database, wherein the
`data is acquired electronically, comprising:
`activating a computer terminal;
`a.
`b.
`accessing an applications program for access to the data;
`c.
`accessing a data entry screen and entering a parcel attribute to call up the parcel
`selected;
`d.
`subsequently accessing a multi-state parcel map database comprising multiple
`jurisdictional databases which have been normalized to a common data protocol;
`e.
`generating a spatial query involving, as needed, city, state, zip code and Assessor's
`Parcel Number to access the correct portion of the multi state data base to retrieve the
`pertinent map information; and,
`f.
`thereafter displaying on screen a parcel boundary polygon map, along with
`surrounding parcel boundary polygons, the default scale of the displayed map selected to fill
`the computer display screen with parcel boundaries within a selected distance around the
`subject parcel, the selected parcel boundary polygon highlighted, defining both the location
`and boundary of the parcel, and associated attribute data for the highlighted parcel
`displayed.
`
`
`
`
`
`IPR2015-00226
`Claim Constructions
`
`58
`
`
`
`“multi-state parcel map database”
`
`Board
`collection of data relating to two or more
`jurisdictions (Dec. at 6)
`
`Patent Owner
`a database covering more than one state
`and including multiple jurisdictional
`databases, wherein a jurisdictional
`database is a collection of data
`representing the boundaries of parcels
`from the jurisdiction, each of the
`jurisdictional databases having been
`received from a jurisdiction and modified,
`transformed, amended or converted by a
`common set of one or more processes
`applied to all data and updates (Resp. at
`8)
`
`IPR2015-00226 Reply at 2-5
`
`59
`59
`
`
`
`“jurisdiction”
`
`Board
`No construction offered (Dec. at 6-8)
`
`Patent Owner
`No formal construction offered (Resp. at 7-
`17)
`
`IPR2015-00226 Reply at 5-6
`
`60
`60
`
`
`
`“jurisdictional identifier”
`
`Board
`a number or other name, code, or
`description that identifies a
`jurisdiction (Dec. at 6-8)
`
`Patent Owner
`No formal construction offered*
`(Resp. at 7-17)
`
`IPR2015-00226 Reply at 6-7
`
`61
`61
`
`
`
`IPR2015-00226
`Harder and Longley
`(claims 1-10 and 12-21)
`
`62
`
`
`
`Patent Owner: Harder and Longley Issues
`
`• Patent Owner argues Harder does not disclose a “multi-state”
`database” or normalized data (Resp. at 23-24)
`• Patent Owner argues Longley does not disclose a jurisdictional
`identifier, indexing, and a multi-state database (Resp. at 24-
`31)
`
`IPR2015-00226 Reply at 8-18; PO Resp. at 22-31
`
`63
`63
`
`
`
`Limitations at Issue
`
`64
`64
`
`1. An interactive computer implemented method for retrieving geographic parcel boundary
`polygon maps and associated parcel attribute data linked to a non-graphic database, wherein the
`data is acquired electronically, comprising:
`activating a computer terminal;
`a.
`b.
`accessing an applications program for access to the data;
`c.
`accessing a data entry screen and entering a parcel attribute to call up the parcel
`selected;
`d.
`subsequently accessing a multi-state parcel map database comprising multiple
`jurisdictional databases which have been normalized to a common data protocol;
`e.
`searching a jurisdiction look up table associated with the multi-state parcel map
`database, said look up table indexed for identification of the pertinent jurisdictional
`database, whereby a jurisdictional identifier for the selected jurisdiction is located, and the
`identified jurisdictional database thereafter accessed; and,
`f.
`thereafter displaying on screen a parcel boundary polygon map, along with
`surrounding parcel boundary polygons, the default scale of the displayed map selected to fill
`the computer display screen with parcel boundaries within a selected distance around the
`subject parcel, the selected parcel boundary polygon highlighted, defining both the location
`and boundary of the parcel, and associated attribute data for the highlighted parcel
`displayed.
`
`
`
`
`
`IPR2015-00226
`Harder, Longley, and Roy
`(claim 11)
`
`65
`
`
`
`Claim 11
`
`PO Resp. at 31-32
`
`IPR2015-00226 PO Resp. at 31-32; Reply at 18-19
`
`66
`66
`
`
`
`IPR2015-00226
`Kearney and ARC/INFO
`(claims 1-6 and 20-21)
`
`67
`
`
`
`Patent Owner: Kearney and ARC/INFO Issues
`
`• Patent Owner argues Kearney does not disclose multiple
`jurisdictional databases, normalized data, jurisdictional
`identifiers, or indexing (Resp. at 32-33)
`• Patent Owner argues that ARC/INFO does not disclose
`multiple jurisdictional databases, normalized data,
`jurisdictional identifiers, or indexing (Resp. at 33-35)
`
`IPR2015-00226 PO Resp. at 32-35
`
`68
`68
`
`
`
`Patent Owner: Kearney Issues
`
`PO Resp. at 32-33
`
`IPR2015-00226 PO Resp. at 32-33
`
`69
`69
`
`
`
`Kearney
`
`Ex. 1021 at 575
`
`Ex. 1021 at 578
`
`Ex. 1021 at 576
`
`IPR2015-00226 Pet. at 50-51; Reply at 19-20
`
`70
`70
`
`
`
`Kearney
`
`IPR2015-00226 Pet. at 50-51; Reply at 19-20
`
`Ex. 1021 at 578
`
`71
`71
`
`
`
`ARC/INFO
`
`IPR2015-00226 Pet. at 50-54; Reply at 21
`
`72
`72
`
`Ex. 1004 at 3-6
`
`
`
`ARC/INFO
`
`ARC/INFO
`
`LIBBA F1‘.-‘AN
`
`A set of software tools used to manage and access large geographic
`data sets in a map library. A map library is a. collection of spatial tiles
`used to spatially pa11ition large areas and layers used to thematically
`organize geographic data. LIBRARIAN comrnands create and define
`a map library, move data in and out of a library, query the data in a
`map library, and display the results of a query. See also map library.
`
`Ex. 1004 at Glossary-24
`EX. 1004 at Glossary-24
`
`map library
`
`An organized, uniformly defined collection of spatial data paiiitioned
`by layers and tiles into component parts. Map libtaiies organize
`geographic data spatially as a set of tiles and thematically as a set of
`layers. The data in a map library are indexed by location for optimal
`spatial access.
`
`EE 2
`
`80115
`
`Soils
`Streams I
`
`_
`
`A amp l:}’mIi'y' ui'g£mi'zrr.s' e'01=c’:'ci'gc:.2.' spaticrl'!y by H'.I'e.s' t.-rid Ilxemnfirrnfly b_1,= icxycw.
`Iritlitrizlttal r.'r2w::Iigr:.tfm' anew": ln_3=r.’.=‘ wirlnn -11 tile are calico’ .'rr-up .s'ecr‘r'0n:.'.
`
`Ex. 1004 at Glossary-28
`EX. 1004 at Glossary-28
`
`IPR2015-00226 Pet. at 50-54; Reply at 21-22
`IPR2015-00226 Pet. at 50-54; Reply at 21-22
`
`73
`73
`
`
`
`ARC/INFO
`
`ARC/INFO
`
`The spatial unit by which geographic data is organized, subdivided,
`and stored in a map library. Tiles subdivide the area covered by a map
`library and organize the library data by location [e.g., counties might
`be the tiles in a statewide database). A ti le can be a icgular, geometric
`shape (e.g., a map sheet}, or an i1't'e_gu|ar' shape, such as a county
`boundary. See also LIBRARIAN.
`
`Ex. 1004 at Glossary-48
`EX. 1004 at Glossary-48
`
`workspace
`
`A directory containing geographic data sets for use with ARCIINFO.
`A workspace contains an INFO directory for the feature attribute
`tables. ARCHNFO workspaces have three primary uses: as user
`work areas, to store all the map sections for each tile in a map library,
`and as automation worl<spaces to store all the versions of a single
`coverage as il. progresses through the coverage automation process.
`
`Ex. 1004 at Glossary-51
`EX. 1004 at Glossary-51
`
`dr'recrc.-ry
`
`A location oil a disk containillg :1 set of data files and other directories
`(subdirectories). Operating systems use directories to organize data.
`Directories a1'e organized in a tree structure in which each branch on
`the tree represents a subdirectory. The location of a directorgr is
`specified with a ;J.r:.ri'm.:rme (e.g., Idiskfproject_db!tilc202r‘soilsc(w).
`
`disk
`pre]?ct_dto
`iiie202
`
`|
`tile2t}O
`
`I
`li!e2D1
`
`r
`ti|e203
`
`I
`ti|e2U4
`
`I
`Iandusecotr damgrld
`tic
`arc
`
`—" ‘W’?!
`soillscov
`streamscov
`pat
`pal
`bnd
`
`Ex. 1004 at Glossary-12
`EX. 1004 at Glossary-12
`
`IPR2015-00226 Pet. at 50-54; Reply at 21-22
`IPR2015-00226 Pet. at 50-54; Reply at 21-22
`
`74
`74
`
`
`
`Patent Owner: ARC/INFO
`
`Ex. 1034 at 82:12-15
`
`Ex. 1034 at 85:16-19
`
`Ex. 1034 at 85:3-10
`
`IPR2015-00226 Reply at 22
`
`Ex. 1034 at 92:2-11
`
`75
`75
`
`
`
`Patent Owner: ARC/INFO
`
`Ex. 1034 at 99:9-15
`
`Ex. 1034 at 99:16-22
`
`Ex. 1034 at 101:10-14
`
`Ex. 1034 at 100:8-10
`
`IPR2015-00226 Reply at 22-23
`
`76
`76
`
`
`
`Patent Owner: ARC/INFO
`
`Ex. 1034 at 94:21-95:6
`
`Ex. 1034 at 96:16-21
`
`Ex. 1034 at 97:3-15
`
`IPR2015-00226 Reply at 22-23
`
`77
`77
`
`
`
`Instituted Grounds
`(IPR2015-00228)
`U.S. Patent No. 7,092,957
`
`78
`
`
`
`Instituted Grounds: IPR2015-00228
`
`• 35 U.S.C. § 103
`– Claims 1-10 and 12-19 are obvious over Harder and
`Longley
`– Claim 11 is obvious over Harder, Longley, and Roy
`– Claims 1-8 and 16-19 are obvious over Kearney and
`ARC/INFO
`
`
`
`IPR2015-00228 Institution Decision at 21
`
`79
`79
`
`
`
`80
`80
`
`’957 Patent Claims
`
`1. An interactive computer implemented method for retrieving geographic parcel boundary
`polygon maps and associated parcel attribute data linked to a non-graphic database, wherein the
`data is acquired electronically, comprising:
`activating a computer terminal connected to a computer network;
`a.
`accessing an applications program for access to the data;
`b.
`accessing a data entry screen and entering a parcel attribute to call up the parcel selected;
`c.
`d. subsequently accessing a national parcel map database comprising multiple jurisdictional
`databases which have been normalized to a common data protocol;
`e. searching a jurisdiction look up table associated with the national parcel map database,
`said look up table indexed for identification of the pertinent jurisdictional database, whereby
`a numerical jurisdictional identifier for the selected jurisdiction is located, and the identified
`jurisdictional database thereafter accessed; and,
`f. thereafter displaying on screen a parcel boundary polygon map, along with surrounding
`parcel boundary polygons, the default scale of the displayed map selected to fill the computer
`display screen with parcel boundaries within a selected distance around the subject parcel,
`the selected parcel boundary polygon highlighted, defining both the location and boundary of
`the parcel, and the associated attribute data for the highlighted parcel displayed.
`
`
`
`
`
`IPR2015-00228
`Claim Constructions
`
`81
`
`
`
`“national parcel map database . . .”
`
`Board
`No construction offered (Dec. at 6-
`8)
`
`Patent Owner
`“national parcel map database comprising multiple
`jurisdictional databases which have been
`normalized to a common data protocol parcel
`boundary map database” means “a database
`covering more than one state including multiple
`jurisdictional databases, wherein a jurisdictional
`database is a collection of data representing the
`boundaries of parcels from the jurisdiction, each of
`the jurisdictional databases having been received
`from a jurisdiction, and modified, transformed,
`amended or converted by a common set of one or
`more processes applied to all data and updates.”
`(Resp. at 8-15)
`
`IPR2015-00228 Reply at 2-5
`
`82
`82
`
`
`
`“jurisdiction”
`
`Board
`No construction offered (Dec. at 6-8)
`
`Patent Owner
`No formal construction offered* (Resp. at
`7-15)
`
`IPR2015-00228 Reply at 6
`
`83
`83
`
`
`
`“numerical jurisdictional identifier”
`
`Board
`a number that identifies a jurisdiction
`(Dec. at 5-8)
`
`Patent Owner
`No formal construction offered*
`(Resp. at 7-15)
`
`IPR2015-00228 Reply at 7-8
`
`84
`84
`
`
`
`IPR2015-00228
`Harder and Longley
`(claims 1-10 and 12-19)
`
`85
`
`
`
`Patent Owner: Harder and Longley Issues
`
`• Patent Owner argues Harder does not disclose a “national”
`database or normalized data (Resp. at 22-23)
`• Patent Owner argues Longley does not disclose jurisdictional
`identifier, indexing, or a national database (Resp. at 23-29)
`
`IPR2015-00228 Reply at 9-19; PO Resp. at 22-29
`
`86
`86
`
`
`
`Limitations at Issue
`
`1. An interactive computer implemented method for retrieving geographic parcel boundary
`polygon maps and associated parcel attribute data linked to a non-graphic database, wherein the
`data is acquired electronically, comprising:
`activating a computer terminal connected to a computer network;
`a.
`accessing an applications program for access to the data;
`b.
`accessing a data entry screen and entering a parcel attribute to call up the parcel selected;
`c.
`d. subsequently accessing a national parcel map database comprising multiple jurisdictional
`databases which have been normalized to a common data protocol;
`e. searching a jurisdiction look up table associated with the national parcel map database,
`said look up table indexed for identification of the pertinent jurisdictional database, whereby
`a numerical jurisdictional identifier for the selected jurisdiction is located, and the identified
`jurisdictional database thereafter accessed; and,
`f. thereafter displaying on screen a parcel boundary polygon map, along with surrounding
`parcel boundary polygons, the default scale of the displayed map selected to fill the computer
`display screen with parcel boundaries within a selected distance around the subject parcel,
`the selected parcel boundary polygon highlighted, defining both the location and boundary of
`the parcel, and the associated attribute data for the highlighted parcel displayed.
`
`
`
`Ex. 1001, ’957 Patent at claim 1
`
`87
`87
`
`
`
`IPR2015-00228
`Harder, Longley, and Roy
`(claim 11)
`
`88
`
`
`
`Claim 11
`
`PO Resp. at 30
`
`IPR2015-00228 Reply at 19; PO Resp. at 30
`
`89
`89
`
`
`
`IPR2015-00228
`Kearney and ARC/INFO
`(claims 1-8 and 16-19)
`
`90
`
`
`
`Patent Owner: Kearney and ARC/INFO Issues
`
`• Patent Owner argues Kearney does not disclose multiple
`jurisdictional databases, a jurisdictional identifier, or indexing
`(Resp. at 30-32)
`• Patent Owner argues that ARC/INFO does not disclose
`multiple jurisdictional databases, normalized data,
`jurisdictional identifiers, or indexing (Resp. at 32-35)
`
`IPR2015-00228 PO Resp. at 30-35
`
`91
`91
`
`
`
`Kearney
`
`IPR2015-00228 Pet. at 47-53; Reply at 19-24
`
`Ex. 1021 at 578
`
`92
`92
`
`
`
`ARC/INFO
`
`IPR2015-00228 Pet. at 49-53; Reply at 21
`
`93
`93
`
`Ex. 1004 at Glossary-28
`
`
`
`Instituted Grounds
`(IPR2015-00219)
`U.S. Patent No. 8,065,352
`
`94
`
`
`
`Instituted Grounds: IPR2015-00219
`
`• 35 U.S.C. § 102
`– Claims 12-15 and 17-21 are anticipated by Oosterom
`
`
`IPR2015-00219 Institution Decision at 12
`
`95
`95
`
`
`
`IPR2014-00219
`Claim Constructions
`
`96
`
`
`
`Patent Owner’s Constructions
`
`IPR2015-00219 Reply at 3
`
`97
`
`
`
`Patent Owner’s Constructions
`
`IPR2015-00219 Reply at 4
`
`98
`
`
`
`IPR2015-00219
`
`IPR2015-00219
`Oosterom
`
`Oosterom
`
`99
`
`99
`
`
`
`Patent Owner: Oosterom Issues
`
`• Patent Owner argues Oosterom does not disclose a multi-
`jurisdictional database, normalized data, or using a
`jurisdictional identifier relating to claim 12 (Resp. at 23, 28-
`33)
`• Patent Owner argues that Oosterom does not disclose the
`indexing and search a portion of the database relating to claims
`19, 20, and 21 (Resp. at 24, 33-38)
`
`IPR2015-00228 PO Resp. at 28-38
`
`100
`100
`
`
`
`Oosterom
`
`Ex. 1010 at 509
`
`Ex. 1010 at 511
`
`IPR2015-00219 Pet. at 43-47
`
`101
`101
`
`
`
`Oosterom
`
`Ex. 1010 at 512
`
`IPR2015-00219 Pet. at 43-47
`
`102
`102
`
`
`
`Oosterom
`
`Ex. 1010 at 513
`
`IPR2015-00219 Reply at 15-17
`
`103
`103
`
`
`
`Oosterom
`
`IPR2015-00219 Reply at 15-17
`
`104
`104
`
`Ex. 1010 at 514
`
`
`
`Oosterom
`
`Ex. 1010 at 519-20
`
`Ex. 1010 at 520
`
`IPR2015-00219 Reply at 15-18
`
`105
`105
`
`
`
`106
`
`106
`
`
`
`CERTIFICATE OF SERVICE
`
`Case IPR2015-00222
`Patent No. 8,065,352
`
`
`I hereby certify that on this 9th day of February, 2016, a copy of the
`
`foregoing Petitioner’s Demonstrative Exhibits was served electronically, pursuant
`
`to agreement, upon the following:
`
`
`
`Lawrence Edelman
`The Law Office
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