Oral Hearing Presentation
`of Patent Owner
`
`CBM2013-00052
`
`October 29, 2014
`
`Versata Exh. 2020
`Callidus v. Versata
`CBM2013-00052
`
`
`of Patent Owner
`
`CBM2013-00052
`
`October 29, 2014
`
`Versata Exh. 2020
`Callidus v. Versata
`CBM2013-00052
`
`
`
`Section 325(a)(1) Bars Institution
`
`“A post-grant review may not be instituted
`under this chapter if, before the date on
`which the petition for such a review is filed,
`the petitioner or real party in interest filed
`a civil action challenging the validity of a
`claim of the patent.”
`
`35 USC § 325(a)(1); Patent Owner’s Response (Paper No. 34) at 33.
`
`October 29, 2014
`
`CBM2013-00052
`
`2
`
`
`
`Section 325(a)(1) Bars Institution
`
`…
`
`Reply at 14.
`
`…
`
`October 29, 2014
`
`CBM2013-00052
`
`Exhibit 2001 at 3.
`
`3
`
`
`
`Section 325(a)(1) Bars Institution
`
`Petitioner: “[N]othing in AIA § 18 incorporates
`Chapter 32 in its entirety for CBM review.”
`
`Petitioner’s Reply (Paper No. 36) at 13.
`
`“The transitional proceeding implemented
`pursuant to this subsection shall be regarded
`as, and shall employ the standards and
`procedures of, a post-grant review under
`chapter 32 of title 35…”
`
`AIA § 18(a)(1).
`
`October 29, 2014
`
`CBM2013-00052
`
`4
`
`
`
`Section 325(a)(1) Bars Institution
`
`Petitioner: “Petitioner’s DJ complaint was
`filed (but never served)...”
`
`Petitioner’s Reply (Paper No. 36) at 14.
`
`October 29, 2014
`
`CBM2013-00052
`
`Exhibit 2011.
`
`5
`
`
`
`’326 Patent – Claim 1
`
`1. In a computer system, a method for collectively
`performing validation of credential
`information of
`one or more product distributors associated with
`one or more product distribution transactions, the
`method comprising:
`credential
`available
`of
`obtaining
`a
`set
`information of each of
`the one or more
`product distributors associated with the one
`or more product distribution transactions;
`storing the set of credential
`information in the
`computer system, wherein the credential
`information is stored in a form that can be
`processed by the computer system;
`loading from at least one data source a set of
`credential validation rule data;
`obtaining the one or more product distribution
`transactions associated with the one or more
`product distributors; and
`processing in the computer system the one or
`more product distribution transactions and
`the credential validation rule data to validate
`
`the obtained one or more product distribution
`transactions associated with the one or more
`product distributors
`in accordance with
`predetermined validation criteria to determine
`if the one or more transactions can be used
`for compensating one or more product
`distributors,
`to
`validate
`the
`obtained
`credential information of one or more product
`distributors associated with one or more
`transactions to determine whether the one or
`more product distributors meet eligibility
`requirements for compensation associated
`with each of the obtained product distribution
`transactions for the one or more product
`distributors, and to generate results data
`representing
`at
`least
`any
`validated
`transactions and determined-eligible product
`distributors; and
`generating compensation data from the results
`data for each of the one or more product
`distributers to be compensated for the one or
`more product distribution transactions.
`
`October 29, 2014
`
`CBM2013-00052
`
`Ex. 1001 (‘326 Patent), col. 15, ll. 17-50.
`
`6
`
`
`
`Petitioner’s Abstract Ideas are Unlike Alice
`
`
`“The proper analysis under the ‘abstract idea’ exception is to “The proper analysis under the ‘abstract idea’ exception is to
`
`first ‘determine whether the claims at issue are directed to a first ‘determine whether the claims at issue are directed to a
`
`patent-ineligible concept.’”patent-ineligible concept.’”
`
`Alice’s categories of abstract ideas:
`•
`“fundamental economic practice[s]”
`•
`“preexisting, fundamental truth[s]”
`•
`“mathematical formulas”
`•
`“an idea of itself”
`
`October 29, 2014
`
`CBM2013-00052
`
`7
`
`Alice Corporation Pty., Ltd. v. CLS Bank Int’l,
`573 U.S. ___, 134 S.Ct. 2347, 2355-56 (2014);
`Patent Owner’s Response (Paper No. 34), pp. 12-15.
`
`
`
`Petitioner Has Not Satisfied Its Statutory Burden
`
`
`Evidentiary Standards. – In a post-grant review instituted under this Evidentiary Standards. – In a post-grant review instituted under this
`
`chapter, the petitioner shall have the burden of proving a proposition of chapter, the petitioner shall have the burden of proving a proposition of
`
`unpatentability by a preponderance of the evidence.unpatentability by a preponderance of the evidence.
`
`35 USC § 326(e).
`
`Petitioner has presented no factual
`evidence to support a finding that its
`“abstract idea” is a fundamental economic
`concept or within the other categories of
`“abstract ideas” analyzed by the Alice court.
`
`Patent Owner’s Response (Paper No. 34), p. 14.
`
`October 29, 2014
`
`CBM2013-00052
`
`8
`
`
`
`’326 Patent – Dependent Claims
`
`2. The method of claim 1 wherein said obtaining
`said set of available credential
`information further
`comprises denormalizing data from a plurality of
`database tables.
`
`claim 9 wherein said
`12. The method of
`denormalizing said set of credential
`information
`further comprises joining at
`least
`two database
`tables into at least one database table.
`
`17. The method of claim 9 wherein said applying a
`credential test further comprises joining said set of
`test conditions data with said denormalized
`database table.
`
`9. The method of claim 1 further comprising:
`obtaining the set of available credential
`information for at least one of the distributors
`from two or more tables;
`denormalizing said set of available credential
`information from said two or more tables into
`a denormalized database table;
`wherein the rule data comprises a set of test
`conditions data from at
`least one data
`source; and
`processing in the computer system the rule data
`comprises applying a credential
`test by
`querying said denormalized table with said
`set of test conditions data.
`
`October 29, 2014
`
`CBM2013-00052
`
`9
`
`Ex. 1001 (‘326 Patent), col. 15, l. 51 – col. 16, l. 53.
`
`
`
`Claim Construction – “denormalizing”
`
`Petitioner’s Construction
`
`
`The BRI of “denormalizing” is “creating a The BRI of “denormalizing” is “creating a
`
`redundant copy” of information.redundant copy” of information.
`Petition (Paper No. 11) at 21.
`Specification Appearance
`of Petitioner’s Construction
`
`Patent Owner’s Response (Paper No. 34) at 6.
`Petitioner’s Extrinsic Evidence In
`Support
`
`Patent Owner’s Response (Paper No. 34) at 6.
`Petitioner’s Reply Argument In
`Support
`
`Patent Owner’s Response (Paper No. 34) at 6.
`
`October 29, 2014
`
`CBM2013-00052
`
`Patent Owner’s Construction
`
`a database operation which, in a database operation which, in
`
`conjunction with specific programming, conjunction with specific programming,
`
`creates a representation of data stored in creates a representation of data stored in
`
`two or more database tables joined two or more database tables joined
`
`according to specified criteriaaccording to specified criteria
`Patent Owner’s Response (Paper No. 34) at 11.
`Patent Owner’s Extrinsic
`Evidence In Support
`Denormalization – “the reverse of normalization.
`Relations are merged thereby possibly
`introducing redundancy and the potential for
`anomalies. Denormalization is often used to
`increase the efficiency of certain queries as the
`number of required joins is reduced.”
`
`Ex. 2015
`“[D]enormalization is still one issue that lacks
`solid principles and guidelines.”
`
`Ex. 2017
`10
`
`
`
`Claim Construction – “joining”
`
`Petitioner’s Allegation
`
`Patent Owner’s Interpretation
`
`
`“’[J]oining’…simply means ‘looking up’ “’[J]oining’…simply means ‘looking up’
`
`information...”information...”
`
`Petition (Paper No. 11) at 45.
`Petitioner’s Intrinsic Evidence In
`Support
`
`Patent Owner’s Response (Paper No. 34) at 30-31.
`Petitioner’s Extrinsic Evidence In
`Support
`
`Patent Owner’s Response (Paper No. 34) at 30-31.
`Petitioner’s Reply Argument In
`Support
`
`Patent Owner’s Response (Paper No. 34) at 6, 30-31.
`
`October 29, 2014
`
`CBM2013-00052
`
`“‘[J]oin’ is defined as ‘a database table
`operation that creates a resultant entry in
`another table for each entry in the one
`table whose key field matches that of an
`entry in the other.’”
`
`Patent Owner Response (Paper No. 34) at 31, Ex. 2016.
`[A] “join” is “in languages operating on
`databases, an operator used to combine
`related tuples from two relations into single
`operations. Only operations that satisfy the
`join condition appear in the result of the
`operation. In SQL, a JOIN TABLE allows
`users to specify a table resulting from a
`join operation in the FROM clause of a
`query.”
`
`Ex. 2015
`
`11
`
`
`
`Oral Hearing Presentation
`of Patent Owner
`
`CBM2013-00052
`
`October 29, 2014
`
`
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