`IPR2015-00222 Paper No. 47
`IPR2015-00226 Paper No. 49
`IPR2015-00228 Paper No. 49
`March 14, 2016
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`trials@uspto.gov
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`571-272-7822
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`CORELOGIC, INC.,
`Petitioner,
`
`v.
`
`BOUNDARY SOLUTIONS, INC.,
`Patent Owner.
`____________
`
`IPR2015-00219 (Patent 8,065,352 B2)
`IPR2015-00222 (Patent 8,065,352 B2)
`IPR2015-00226 (Patent 7,499,946 B2)
`IPR2015-00228 (Patent 7,092,957 B2)
`____________
`
`Held: February 11, 2016
`____________
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`
`
`BEFORE: LYNNE E. PETTIGREW, PETER P. CHEN, and
`RICHARD H. MARSCHALL, Administrative Patent Judges.
`
`
`
`The above-entitled matter came on for hearing on Thursday,
`February 11, 2016, commencing at 2:00 p.m., at the U.S. Patent
`and Trademark Office, 600 Dulany Street, Alexandria, Virginia.
`
`
`
`
`
`IPR2015-00219 (Patent 8,065,352 B2); IPR2015-00222
`(Patent 8,065,352 B2); IPR2015-00226 (Patent 7,499,946 B2);
`IPR2015-00228 (Patent 7,092,957 B2)
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`
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`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`JOSEPH E. PALYS, ESQ.
`DANIEL ZEILBERGER, ESQ.
`NAVEEN MODI, ESQ.
`Paul Hastings LLP
`875-15th Street, N.W.
`Washington, D.C. 20005
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`ON BEHALF OF PATENT OWNER:
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`LAWRENCE EDELMAN, ESQ.
`The Law Offices of Lawrence Edelman
`130 San Aleso Avenue
`San Francisco, California 94127
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`and
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`BRUCE J. WECKER, ESQ.
`Hausfeld
`600 Montgomery Street, Suite 3200
`San Francisco, California 94111
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`IPR2015-00219 (Patent 8,065,352 B2); IPR2015-00222
`(Patent 8,065,352 B2); IPR2015-00226 (Patent 7,499,946 B2);
`IPR2015-00228 (Patent 7,092,957 B2)
`P R O C E E D I N G S
`- - - - -
`JUDGE PETTIGREW: Please be seated.
`Good afternoon, everyone. This is a consolidated
`hearing for four cases, IPR 2015-00219, IPR 2015-00222, both of
`which challenge U.S. patent number 8,065,352. The third case is
`IPR 2015-00226, which challenges patent number 7,499,946.
`And then, finally, IPR 2015-00228, which challenges U.S. patent
`number 7,092,957.
`Petitioner is CoreLogic, Inc. Patent Owner is Boundary
`Solutions, Inc. Each side has 75 minutes to argue. Petitioner has
`the ultimate burden of establishing unpatentability, so Petitioner
`will argue first. Petitioner also may address its motion to exclude
`in its opening argument. Patent Owner then will present its
`opposing argument, and then, finally, Petitioner may use any time
`it has reserved for rebuttal to respond to Patent Owner's
`argument.
`We may take a short break after either Petitioner's
`opening argument or Patent Owner's argument, depending on
`how much time has passed when we reach either one of those
`points.
`
`Judge Chen is joining us by video from our Silicon
`Valley office and won't have the benefit of the visual cues in the
`room. So, when you speak about an exhibit or a demonstrative,
`please begin by identifying it with specificity, including the
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`IPR2015-00228 (Patent 7,092,957 B2)
`particular page or slide number. Also, please be sure to speak
`into the microphone to ensure that Judge Chen can hear you.
`Sometimes we have counsel that tend to wander, but it's
`important to speak into the microphone.
`Before we begin with your arguments, a brief
`housekeeping item, we have Petitioner's objections to Patent
`Owner's -- to some of Patent Owner's demonstratives. We won't
`spend time this afternoon discussing or ruling on any of the
`objections. As you know, the demonstratives are not evidence
`but instead are aids to facilitate the panel's understanding of the
`arguments presented by the parties at the hearing. We think the
`panel is capable of determining whether information in a
`demonstrative is improper, and we will not rely on any such
`information in our final written decisions, nor is there a jury
`present that might be confused by such information.
`Nevertheless, we remind the parties that, as set forth in the Trial
`Practice Guide, at oral argument, a party may rely only on
`evidence that has been submitted previously and may only
`present arguments relied upon in the papers previously submitted.
`Counsel, each of you, when you begin your argument,
`please identify yourself and the party you represent for the record.
`Petitioner, you may begin when ready.
`MR. WECKER: Your Honor, Bruce Wecker for the
`Patent Owner. We have a short response to the objections to the
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`IPR2015-00228 (Patent 7,092,957 B2)
`slides which we're ready to file and we would seek permission to
`file that, if -- if it would be useful.
`JUDGE PETTIGREW: We will address that later when
`I have had a chance to confer with the panel. Let's start the
`arguments for now.
`MR. WECKER: Thank you.
`JUDGE PETTIGREW: All right, Petitioner, you may
`begin when ready. First, do you wish to reserve any rebuttal
`time?
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`MR. PALYS: Yes, Your Honor. I'm shooting for 45
`minutes for rebuttal depending on how our initial arguments go.
`JUDGE PETTIGREW: Forty-five for rebuttal.
`MR. PALYS: Just another -- in response to the
`housekeeping note, Patent Owner's counsel provided us a copy of
`their response to the objections, and we'll just note that they're
`argumentative. So, we will leave it at that.
`JUDGE PETTIGREW: Thank you. We appreciate
`that. We will make a determination on what to do with that later.
`MR. PALYS: I understand.
`May it please the Board, my name is Joseph Palys, and I
`represent the Petitioner, CoreLogic, today in these proceedings.
`I'm joined with my colleagues Naveen Modi and Dan Zeilberger.
`Can we turn to slide 2, please. As the Board has already
`noted, there's four matters here. The 219 and 222 relates to the
`'352 patent; the '946 relates to the -- I'm sorry, the 226 matter
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`IPR2015-00228 (Patent 7,092,957 B2)
`relates to the '946 patent; and the 228 matter relates to the '957
`patent.
`
`As you can see here on slide 2, there's a number of
`grounds that have been instituted by this Board, and we agree
`with the Board's decision to institute review based on the grounds
`you see here. You can see a common theme here. There's a lot of
`prior art that's common across several of the matters.
`Now, Patent Owner, through its responses, has raised a
`few arguments relating to each of these grounds, and so for
`purposes of today, we're going to address certain aspects of those
`arguments and then reserve, you know, the time to rebut as we
`deem accordingly. So, with that, as I mentioned, we will reserve
`roughly around 45 minutes.
`If you would turn to slide 3, please. Before addressing
`the specific issues with respect to these grounds, I want to spend
`just a few moments to go over the background of the alleged
`invention. The patents share a common specification, the '352,
`the '946, and the '957, and they are related to the same invention,
`and that is a GIS environment that uses database components to
`store parcel-related information, basically so you can retrieve it
`and display it for a user.
`Now, slide 3 shows Figure 1 of the '352 patent and it
`highlights some of the aspects of the alleged invention, and one
`of those aspects is the information that's stored in a server or
`database. You can see on the bottom of the slide what can
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`IPR2015-00228 (Patent 7,092,957 B2)
`happen is you might get data that's going to be received, and the
`alleged invention will check to see if that's compliant with a
`particular standard. If it is, it gets uploaded and gets stored into
`the database, but if it isn't, it's made compliant, and then, again,
`it's uploaded and stored in the database. The point here is what's
`sitting in the database is information that's been made compliant
`or been received as compliant, it's all in uniform, standard format.
`Figure 1 also shows, you know, what do you use this
`information for, and that could be receiving a request for certain
`information that's in the database, and in response, you'd look for
`that information, pull it up, and you display it.
`If you could turn to slide 4, please. So, slide 4 shows an
`excerpt from one portion of the '352 patent, in particular, in
`column 4, lines 50 through 64, and it explains an example, that
`one of the requests could be you want to have a request for a
`street address for a particular parcel, and the patent explains,
`based on the state that's identified in the request or associated
`with the request, the process will access a folder including all the
`files for that state. It's going to locate that requested information,
`pull it up, and display it.
`Thus, at a very high level, what we're looking at here is
`the patents describe storing information in a database, in some
`uniform, common format, according to a standard, and then
`accessing that data locating it, pulling it up, and displaying it.
`But to accomplish these features, Your Honors, the patents in the
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`IPR2015-00228 (Patent 7,092,957 B2)
`alleged invention really just incorporate known, conventional
`database techniques and components.
`Turn to slide 5, please. Patent Owner's expert
`acknowledged that Patent Owner did not invent certain of these
`aspects. You can see here on slide 5, Patent Owner's expert
`agreed, Patent Owner didn't invent the use of databases in GIS
`systems; they didn't invent the use of directories, files, or tables to
`store information in these databases; they didn't invent the use of
`identifiers to identify the files that are stored or tables in these
`databases; and they didn't invent the concept of indexing which is
`used to locate information in a database in an efficient manner so
`you don't have to go through all these records, and it optimizes
`the search for information.
`If you would go to slide 6, please. And the patent itself
`actually describes additional conventional features that the Patent
`Owner did not invent. Slide 6 shows an excerpt from column 3,
`line 26, to column 4, line 16 of the '352 patent, and, Your Honors,
`the Patent Owner has acknowledged that this portion of the patent
`is in the prior art, and to be sure, we asked Patent Owner's expert
`during cross examination to confirm that, and he did.
`And what this excerpt really shows is that, as you can
`see from the top, parcel-level GIS technology was mature, it was
`known, and this type of technology was known to use databases
`to store information, including a nongraphical type of database
`that could be linked to a graphical database. It also explains that
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`IPR2015-00228 (Patent 7,092,957 B2)
`-- the use of indexing so you can access particular information in
`the graphical database and to do so so you can receive requested
`parcel data and display it, including surrounding parcel
`information. This is all in this portion of the patent.
`And importantly, the patent acknowledges that in the
`prior art, the digital assemblage from parcel-level databases from
`all the sponsoring agencies is stored in a server system according
`to a standard protocol. That's in the last part of slide 6, looking at
`column 4, lines 8 through 16, roughly. So, what that's saying is
`that the idea of storing information in some uniform, standard
`protocol format, in a GIS environment, was known, was
`conventional.
`Can we turn to slide 7. So, I'm going to begin our
`discussion with respect to the 222 matter, which relates to the
`'352 patent.
`If we go to slide 8. As noted, we believe the Board was
`correct in instituting the -- in instituting the review of the claims
`of the '352 patent, and here are the grounds you see on slide 8.
`With respect to Harder and Du, this is prior art, Harder and Du,
`Harder, Du, and MacDonald, and Harder and Longley.
`Now, again, we are going to touch on certain issues that
`we believe that the Patent Owner has focused these proceedings
`on based on its responses, but before we get into that, just to
`touch on the claims, let's look at slide 9, please.
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`IPR2015-00228 (Patent 7,092,957 B2)
`Slide 9 shows one of the independent claims in the '352
`patent, it's claim 12, and slides 9 through 11 will show the
`independent claims. What's shown here, really, when you're
`looking at the claims, it boils down to receiving a request for
`parcel data. You're going to search a multijurisdictional database,
`using a jurisdictional identifier. The information in that database
`is normalized, and then you're going to transmit parcel data and
`display it.
`Go to slide 10, please. Claim 9 tracks the limitations
`largely of claim 12. There is a slight additional feature, which is
`having a jurisdictional identifier from an index.
`Go to slide 11, please. And claim 1, again, tracks
`largely the limitations that you'll find in claim 12, but it also
`includes these limitations related to service area directories.
`Slide 12, thank you. Now, I want to touch on claim
`construction a little bit, and we believe, again, that the Board was
`correct in its interpretations regarding claim construction in its
`decision for the '352 patent. Under the Board's constructions and
`under -- even under the Petitioner's proposed constructions in its
`petitions, we think the prior art reads on the claims of the '352
`patent.
`
`Now, Patent Owner has submitted its proposed
`constructions for certain terms, and in doing so, it raises several
`issues, but sometimes it actually introduces constructions that are
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`IPR2015-00228 (Patent 7,092,957 B2)
`more narrow here in these proceedings than what they proposed
`in District Court.
`For purposes of today, though, what we're going to do is
`we're going to wait to hear from Patent Owner regarding their
`positions on claim construction, and we will focus and rebut
`accordingly. Our papers address the issues, but there are a couple
`points I want to point out before moving on to the prior art issues.
`Can we go to slide 14, please. On slide 14, one of -- it
`identifies one of the issues, and that's the term "jurisdiction."
`You can see, just represented in the slide, in its papers, the Patent
`Owner didn't really formally propose a construction for this term,
`but how the Patent Owner and Patent Owner's expert has applied
`the meaning of this term with respect to the prior art we think is
`instructive. It implies a way that they're interpreting it.
`For example, in its responses, the Patent Owner has
`made an attempt to distinguish prior art based on the use of
`county, FIPS identifiers, and these county directories. Examples
`of these are in its response on page 2, discussing the reference for
`Du; page 15, discussing constructions of multijurisdictional
`databases and county jurisdictional databases; page 39, again,
`relating to Du; pages 45, 47, and 49 -- or 49 through 50, relate to
`the reference to Longley.
`You can turn to slide 15, please. And Patent Owner's
`expert even has a very limited interpretation of the term
`"jurisdiction" and in the context of the claims. We asked the
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`IPR2015-00228 (Patent 7,092,957 B2)
`expert, we say, well, what is your understanding, in the context of
`the claims, of jurisdiction? And he told us, it has to be -- first --
`it's two things. First, it has to be serviced by a public agency.
`Well, that's inconsistent with the patent specification, which notes
`that data sponsors, which provide the data for uploading into the
`database, they can be private. An example of that is in column 2,
`lines 49 through 54 of the patent.
`The second point here is that the Patent Owner has
`attached a condition to the term which requires basically a
`jurisdiction to invest money before it can be considered a
`jurisdiction in the context of the claims, and I think that last part
`is important. This is how he applies his understanding of the
`jurisdiction when he does his analysis for the patents, and the
`Patent Owner heavily relies on its expert.
`JUDGE PETTIGREW: Let's assume that we agree with
`you that "jurisdiction" is broader than "county" and doesn't
`require data that's received from a single agency. Can we move
`on to -- I don't know if you have other claim construction issues
`at this point. We would actually like you to get to your
`obviousness and anticipation cases rather than spending too much
`time on claim construction at this point.
`MR. PALYS: Sure. I actually was going to move on
`right past this. So, I hit a good point. Jurisdictional identifier, we
`can -- which is on slide 17, same issues, so we will just move on
`according to Her Honor's instruction.
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`IPR2015-00228 (Patent 7,092,957 B2)
`So, let's move to slide 26 and let's talk about the
`positions with Harder and Du. Go to slide 29. Again, the fact --
`we talked about claim 12, what it -- what it covers. The
`highlighted portions you see on slide 29 is really just visually
`showing you some of the issues that were raised by Patent Owner
`in its response, and that's where the focus is at.
`If we can go to slide 27. Now, we believe, based on the
`responses, there's four issues raised by Patent Owner, and as to
`the first issue, you see on slide 27, with respect to Harder, the
`Patent Owner's arguments really focus on Harder alone and do
`not consider the combination of Harder with Du, and for that
`reason should be rejected. And also, it relies on its unreasonable
`claim constructions, which we believe and I believe that the
`Board disagreed with as well.
`With respect to the second issue and the normalized
`data aspects of the claims, again, Patent Owner's arguments really
`focus in on their -- what we believe is an unreasonable
`interpretation of what the normalized data is, and we think that
`should be rejected, and we believe that the combination does
`teach the normalized data aspects.
`And as to Du, Patent Owner argues that Du doesn't
`disclose a multijurisdictional database, and it doesn't disclose a
`jurisdictional identifier, but we believe that Du does disclose
`these features.
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`IPR2015-00228 (Patent 7,092,957 B2)
`If we can turn to slide 31, please. Du describes storing
`data in a database that spans multiple jurisdictions, and there's an
`example here in Figure 3 and corresponding descriptions in the
`reference that support that. You can see that Du's arrangement is
`set up by a particular partitioning strategy.
`If you can turn to slide 32. And Du explains that the
`data that's stored in this particular partitioning strategy allows the
`information to be retrieved based on a cell ID. Well, what's a cell
`ID? If you go to slide 33, a cell ID is something that uniquely
`identifies a cell, and Du explains that a cell can be assigned
`according to jurisdictions, such as townships, political
`boundaries, et cetera, and it's associated with that partitioning
`strategy like we've seen on Figure 3.
`And importantly, also, as you can see here in the
`example from Du in column 9, is that the cell ID is an index. It's
`something that Du will use to refer to where the information is
`stored, to get the -- in one example, the parcel information for
`that cell.
`JUDGE PETTIGREW: Could you clarify something,
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`please?
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`MR. PALYS: Yes.
`JUDGE PETTIGREW: Is the cell ID -- is your
`argument, then, that the cell ID is the jurisdictional identifier or
`the index?
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`IPR2015-00228 (Patent 7,092,957 B2)
`MR. PALYS: It's -- it's both. It's a jurisdictional
`identifier because it identifies a jurisdiction, especially when the
`cells are arranged according to whatever jurisdiction it can be,
`nationally based, state-based, you know, municipality, et cetera,
`but Du explains, as you can see on the figure here, it's given a --
`in this example a number, 450. It's used as an index as well. So,
`it would be like in the -- in the database, that's where the
`information is stored, and you use an index to find that
`information so you can get to the parcel.
`JUDGE PETTIGREW: So, is it -- the column in the
`database, for example, that they're showing there, is that -- is that
`the index? The claims require -- the claims that involve index,
`for example, claim 9, recites retrieving a jurisdictional identifier
`associated with a selected parcel from an index of a database.
`Could you explain how Du teaches that?
`MR. PALYS: Well, the -- Du explains that the -- the
`cell ID is a unique identifier and that the list is compared against
`this index. So, there's -- Du described, especially in the
`combination of Harder and in view of the obviousness positions,
`that there is an index, and it could be -- I think we've even
`explained that a lookup table or however you want to explain an
`index is something that was well known.
`And, in fact, I think even in column 1 of Du -- and I
`want to confirm this, Your Honor, so I am going to reach over
`and get my prior art reference -- that Du even explains that the
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`IPR2015-00219 (Patent 8,065,352 B2); IPR2015-00222
`(Patent 8,065,352 B2); IPR2015-00226 (Patent 7,499,946 B2);
`IPR2015-00228 (Patent 7,092,957 B2)
`use of index tables and listings and things of that nature was
`known, and I'll point that out to you in a second.
`In column 1, roughly around column -- lines 50-plus,
`Du is explaining that, you know, the use of index tables and
`separate index tables were known, and that's the whole concept of
`indexing, is you have a separate way of -- you first access the
`index, just like you would in a book, if you will, if I want to find
`some particular information, I'd go there first, this list, where do I
`find that information? And then I'd go there. That's essentially
`what Du's using these cell IDs for.
`JUDGE PETTIGREW: So, are you saying the index,
`then, is the list of cell IDs?
`MR. PALYS: Yes, there could be -- you know,
`however that list is going to be arranged, there's going to be some
`sort of way of being compared to that list so you can go and find
`the particular cell.
`JUDGE PETTIGREW: All right. So, then, claim 9
`also requires using the jurisdictional identifier that you've gotten
`from the index to search a portion of the multijurisdictional
`database. Is your argument that Du teaches that explicitly?
`MR. PALYS: In combination with Harder and Du, you
`know, under the umbrella of obviousness, and as we point out in
`our papers, we do believe it's taught there. But the idea, like in
`that claim, is going to the portion of the database, is basically
`where is the data located? Let's go there and find what you're
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`(Patent 8,065,352 B2); IPR2015-00226 (Patent 7,499,946 B2);
`IPR2015-00228 (Patent 7,092,957 B2)
`looking for. And you can see here, if we're looking for a
`particular parcel, Du's going to find that. And you're going to use
`the cell ID to get to there first, and, in fact, Du mentions -- if you
`would go back to slide 32, Dan, please -- the idea on the bottom
`right, around column 9, 1 through 5, it's describing the benefits of
`its configuration, and it says, "...the number of records to retrieve
`in response to a browse is substantially reduced."
`And the point here is Patent Owner has made these
`arguments in its response that, A, we have a special indexing that
`reduces the number of -- the amount of information you have to
`search, but that's what indexing does. And as I noted, even Patent
`Owner's expert acknowledged that, that indexing is something
`that was well known, so --
`JUDGE PETTIGREW: So, then, in your obviousness
`analysis, what's the -- what's the portion of the database that's
`being identified?
`MR. PALYS: The portion of the database that's being
`identified could be where is that information, so if the cell ID is
`pointing you to, like, the 450 or however it's arranged in the
`configuration of the database, and keep in mind that Du says
`there's no restrictions -- and Patent Owner's expert acknowledged
`this -- no restrictions on how you can arrange the database in
`terms of the geographic extent, whether you want to represent
`certain types of geographic areas and what -- how much
`information you want to put in these tables or its database. But
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`IPR2015-00228 (Patent 7,092,957 B2)
`what's happening is if it -- it will use the cell ID. Where is the
`information that's relevant? It will use the cell ID as an index to
`find that information, which could be a parcel in the particular
`long binary block.
`JUDGE MARSCHALL: If Du does so, are they
`searching the entire database or just that list of cell IDs in the
`table?
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`MR. PALYS: Well, the index will point you to where
`in the database -- the portion, if you will, you know, here's 450,
`and that's the whole idea of indexing, so you don't have to go
`searching through the whole thing. And we have got to keep in
`mind, Your Honors, that especially in the context of at least
`Harder, right, because Harder teaches the idea of using indexing
`and parcel-level searching.
`When you look at this, in the combination of both the
`references, you're taking the -- these known concepts, basically,
`and applying indexing to find where in the database -- the portion
`of the database the information could be, and like in Harder, it
`goes, find that -- find that parcel and then display it.
`JUDGE PETTIGREW: Is there a difference between
`finding the portion of the database and finding the parcel?
`MR. PALYS: To be honest with you, Your Honor,
`even in these proceedings, it -- they could be the same. I think if
`you look at the claims, you could actually view that and say, well,
`the -- where the parcel is is a portion of the database, right? But
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`IPR2015-00228 (Patent 7,092,957 B2)
`it could also be what sometimes Patent Owner is pointing to in
`saying, look, we have a database arrangement that includes
`separate files or directories, and so we're pointing to that directory
`first to go find a parcel. But that's what indexing is doing and
`that's what Du is explaining.
`I mean, boiling down their alleged invention, when you
`look at the claims, and as we are pointing out in the claims,
`looking at -- reviewing in the context of what Patent Owner has
`argued, and even looking at the conventional technologies that
`they admit in their patents and what the Patent Owner has said,
`their alleged invention really boils down to I have a database, and
`maybe I'll separate it into different files, and maybe I'll give these
`files a name, and it just so happens their name wants to be
`something associated with a jurisdiction, even though we think
`they point out sometimes county FIPS numbers, and then use
`indexing, which was well known, to find that file and pull the
`data that's inside that file that you're looking for. I mean, that's
`what their alleged invention boils down to, and we think the prior
`art that's at issue in these proceedings definitely discloses that,
`and even in the context of what one of ordinary skill in the art
`would know at the time, based on their arguments and their
`patent -- and their Patent Owner statements.
`JUDGE PETTIGREW: So, then -- let me just follow
`up, then, because we're talking about more than one reference
`here. What's your best argument for why it would have been
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`IPR2015-00228 (Patent 7,092,957 B2)
`obvious to a person of ordinary skill in the art to combine, in this
`case, Harder and Du in a way that achieves the recited claims?
`You said there's no -- Du teaches essentially there are no
`restrictions on how you can organize this stuff. Why would a
`person of ordinary skill in the art have combined them in the way
`that is claimed in this case in the '352 patent and also the other
`patents?
`MR. PALYS: I don't want to torture what we have in
`our papers, I'll try to be consistent with what we have there, but
`speaking off the cuff here, what you're looking at is, again,
`Harder teaches a parcel-level searching system, okay, and it
`teaches -- you can have a database that stores information.
`There's a dispute whether that could be multiple jurisdictions or
`not, but let's just assume for the case, in the Cabarrus County
`example, that you have a database that spans one county, but the
`whole concept of using indexing to look for where the
`information that you're looking for is disclosed there, and, again,
`well known. When you're looking at Du, it describes in the same
`field, the same idea of doing GIS-based parcel-level searching
`and storing information. Both references disclose the general
`idea of databasing and how you can configure your information.
`And you mentioned about -- my comment on Du,
`saying there's no restriction. The point there is that there's no
`limit on -- I say that tongue in cheek, but there is no real
`restriction in terms of -- you know, if I want to name a file "Joe
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`IPR2015-00228 (Patent 7,092,957 B2)
`Palys File," I can name that. What they're saying is let's name it