UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`FORD MOTOR COMPANY
`Petitioner,
`
`v.
`
`VERSATA DEVELOPMENT GROUP, INC.
`Patent Owner.
`
`______________
`
`
`
`U.S. Patent No. 7,882,057
`
`Case No.: IPR2017-00151
`
`
`
`______________
`
`
`
`DECLARATION OF DR. PHILIP GREENSPUN IN SUPPORT
`OF INTER PARTES REVIEW UNDER 35 U.S.C. § 311 ET SEQ.
`AND 37 C.F.R. § 42.100 ET SEQ. (CLAIMS 1-16, 18-29 AND 31-43
`OF U.S. PATENT NO. 7,882,057)
`
`FORD 1202
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`Patent No. 7,882,057
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`TABLE OF CONTENTS
`
`
`List of Exhibits ........................................................................................................... 5
`
`I.
`
`II.
`
`Qualifications and Professional Experience .................................................... 9
`
`Relevant Legal Standards ..............................................................................15
`
`III. Level of Ordinary Skill in the Art .................................................................16
`
`IV. The ‘057 Patent ..............................................................................................17
`
`V.
`
`The ‘057 Patent Prosecution History .............................................................27
`
`VI. Challenged Claims of the ’057 Patent Viewed in their Broadest
`Reasonable Interpretation ..............................................................................28
`
`VII. Scope and Content of the Prior Art (Summary) ............................................28
`
`VIII. Prior Art: Loomans, U.S. Patent 7,873,503 ...................................................43
`
`IX. Prior Art: “A Customization Approach for Structure Products in
`Electronic Shops” (“Stahl”) ...........................................................................44
`
`X. Ground for Challenge ....................................................................................50
`
`A. Ground 1 – Claims 1-16, 18-29 And 31-43 Are Obvious Based
`On Loomans In View Of Stahl And The General Knowledge Of
`A Person Having Ordinary Skill In The Art .......................................50
`
`1.
`
`Analysis Of Claims 1-16, 18-29, And 31-43 In View Of
`Loomans, Stahl And The General Knowledge Of A
`Person Having Ordinary Skill In The Art .................................50
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`h.
`
`i.
`
`j.
`
`Claim 1 ............................................................................50
`
`Reasons to Combine Loomans with Stahl ......................92
`
`Claim 2 ............................................................................96
`
`Claim 3 ..........................................................................102
`
`Claim 4 ..........................................................................103
`
`Claim 5 ..........................................................................106
`
`Claim 6 ..........................................................................111
`
`Claim 7 ..........................................................................114
`
`Claim 8 ..........................................................................119
`
`Claim 9 ..........................................................................121
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`Claim 10 ........................................................................124
`
`Claim 11 ........................................................................126
`
`k.
`
`l.
`
`m.
`
`Claim 12 ........................................................................129
`
`n.
`
`o.
`
`p.
`
`q.
`
`r.
`
`s.
`
`t.
`
`u.
`
`v.
`
`Claim 13 ........................................................................130
`
`Claim 14 ........................................................................132
`
`Claim 15 ........................................................................135
`
`Claim 16 ........................................................................138
`
`Claim 18 ........................................................................140
`
`Claim 19 ........................................................................153
`
`Claim 20 ........................................................................153
`
`Claim 21 ........................................................................155
`
`Claim 22 ........................................................................155
`
`w.
`
`Claim 23 ........................................................................156
`
`x.
`
`y.
`
`z.
`
`Claim 24 ........................................................................160
`
`Claim 25 ........................................................................160
`
`Claim 26 ........................................................................161
`
`aa. Claim 27 ........................................................................162
`
`bb. Claim 28 ........................................................................164
`
`cc. Claim 29 ........................................................................165
`
`dd. Claim 31 ........................................................................166
`
`ee. Claim 32 ........................................................................175
`
`ff.
`
`Claim 33 ........................................................................176
`
`gg. Claim 34 ........................................................................177
`
`hh. Claim 35 ........................................................................178
`
`ii.
`
`jj.
`
`Claim 36 ........................................................................178
`
`Claim 37 ........................................................................179
`
`kk. Claim 38 ........................................................................179
`
`ll.
`
`Claim 39 ........................................................................180
`
`mm. Claim 40 ........................................................................181
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`nn. Claim 41 ........................................................................182
`
`oo. Claim 42 ........................................................................184
`
`pp. Claim 43 ........................................................................185
`
`XI. Conclusion ...................................................................................................186
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`
`
`List of Exhibits
`
`Exhibit
`Description
`No.
`1201 U.S. Patent No. 7,882,057
`1202
`Expert Declaration of Dr. Philip
`Greenspun
`1203 Curriculum Vitae of Dr. Philip
`Greenspun
`1204 U.S. Patent No. 7,882,057 File History n/a
`
`Date
`Feb. 1, 2011
`n/a
`
`n/a
`
`Identifier
`‘057 Patent
`Greenspun
`Decl.
`Greenspun CV
`
`‘057 Patent File
`History
`Jan. 18, 2011 Loomans
`
`Jun. 2000
`
`Stahl
`
`1992
`
`Kott
`
`2003
`
`Anselma
`
`1205 U.S. Patent No. 7,873,503 to Loomans
`et al.
`1206 A. Stahl, R. Bergmann, S. Schmitt, A
`Customization Approach for
`Structured Products in Electronic
`Shops, Electronic Commerce: The
`End of the Beginning, 13th
`International Bled Electronic
`Commerce Conference (June 19-21,
`2000)
`1207 Alexander Kott, Gerald Agin, David
`Fawcett, Configuration Tree Solver: A
`Technology for Automated Design
`and Configuration, ASME Journal of
`Mechanical Design 114(1): 187-195
`(1992)
`L. Anselma, D. Magro, and P.
`Torasso, Automatically Decomposing
`Configuration Problems, AI*IA 2003:
`Advances in Artificial Intelligence,
`Lecture Notes in Computer Science,
`Volume 2829, pp. 39-52 (2003)
`
`1208
`
`Page 5 of 186
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`
`1210
`
`1211
`
`Exhibit
`Description
`No.
`1209 D. Magro and P. Torasso,
`Decomposing and Distributing
`Configuration Problems, Artificial
`Intelligence: Methodology, Systems,
`and Applications, Lecture Notes in
`Computer Science, Volume 2443, pp.
`81-90 (2002)
`Judith Bachant, John McDermott, R1
`Revisited: Four Years in the Trenches,
`AI Magazine Volume 5, Number 3
`(1984)
`John McDermott, R1: A Rule-Based
`Configurer of Computer Systems,
`Artificial Intelligence (1982)
`1212 Bryan M. Kramer, Knowledge-Based
`Configuration of Computer Systems
`Using Hierarchial Partial Choice,
`IEEE (1991)
`1213 Bei Yu and Hans Jorgen Skovgaard, A
`Configuration Tool to Increase
`Product Competitiveness, IEEE
`Intelligent Systems, 34-41
`(July/August 1998)
`1214 U.S. Patent Application Publication
`No. 2003/0187950 to Rising
`1215 Martin R. Wagner, Understanding the
`ICAD System, ICAD, Inc., 1990
`1216 Oracle Configurator Developer, User’s
`Guide, Release 11i for Windows
`95/98/2000 and Windows NT 4.0
`Stefan Schulz, CBR-Works A State-
`of-the-Art Shell for Case-Based
`Application Building, TECINNO
`GmbH, 1999
`
`1217
`
`Date
`2002
`
`Identifier
`Magro
`
`1984
`
`Bachant
`
`1982
`
`McDermott
`
`1991
`
`Kramer
`
`1998
`
`Yu
`
`Oct. 2, 2003 Rising
`
`1990
`
`ICAD
`
`April 2002
`
`Oracle
`
`1999
`
`CBR Works
`Paper
`
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`Exhibit
`Description
`No.
`1218 Richard M. Stallman and Gerald Jay
`Sussman, Forward Reasoning and
`Dependency-Directed Backtracking In
`a System for Computer-Aided Circuit
`Analysis, MIT Artificial Intelligence
`Laboratory, Memo No. 380, Sept.
`1976
`1219 Bergmann Declaration
`
`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`
`Date
`
`Identifier
`
`Sept. 1976
`
`Stallman
`
`Oct. 14,
`2016
`Oct. 3, 2016
`1992
`
`10/28/15
`
`5/7/15
`
`10/14/15
`
`11/5/15
`
`11/30/15
`
`12/3/15
`
`3/16/15
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1223
`
`1224
`
`1225
`
`Schmitt Declaration
`1220
`1221 Winston Textbook
`1222
`Ford v. Versata, Versata Answer &
`Counterclaims (Dkt. #59)
`Versata v. Ford, Versata Complaint
`(Dkt. #1)
`Ford v. Versata, Opinion and Order
`Denying Motion to Dismiss (Dkt. #55)
`Versata v. Ford, Order to File Notice
`of Good Cause (Dkt. #68)
`Versata v. Ford, Versata Notice
`Regarding Dismissal (Dkt. #69)
`Versata v. Ford, Order of Dismissal
`(Dkt. #70)
`Ford v. Versata, Amended Complaint
`(Dkt. #6)
`
`1226
`
`1227
`
`1228
`
`
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`
`I, Philip Greenspun, hereby declare as follows:
`
`
`
`1.
`
`I am making this declaration at the request of Ford Motor Company in
`
`the matter of Inter Partes Review of U.S. Patent No. 7,882,057 (“the ‘057 Patent”)
`
`to Little.
`
`2.
`
`I am a salaried non-owner employee of Fifth Chance Media LLC,
`
`which is being compensated for my work in this matter at a rate of $475/hour. My
`
`compensation in no way depends on the outcome of this proceeding.
`
`3.
`
`In preparation of this declaration, I have studied the exhibits as listed
`
`in the Exhibit List shown above. Each of these exhibits is a true and accurate
`
`copy.
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`
`
`(a) The documents listed above as well as additional patents and
`
`documents referenced herein;
`
`
`
`(b) The relevant legal standards, including the standard for
`
`obviousness provided in KSR International Co. v. Teleflex, Inc., 550 U.S.
`
`398 (2007), and any additional legal standards set forth in the body of this
`
`declaration; and
`
`
`
`(c) My knowledge and experience based upon my work and study
`
`in this area as described below.
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`
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`
`I.
`
`Qualifications and Professional Experience
`
`5.
`
`I have provided my full background in the curriculum vitae that is
`
`attached as Exhibit 1203.
`
`6.
`
`I earned a Ph.D. in Electrical Engineering and Computer Science from
`
`Massachusetts Institute of Technology in 1999. I also obtained a Bachelor of
`
`Science Degree in Mathematics from Massachusetts Institute of Technology in
`
`1982 and a Master of Science Degree in Electrical Engineering and Computer
`
`Science from Massachusetts Institute of Technology in 1993.
`
`7. My Ph.D. dissertation concerned the engineering of large online
`
`Internet communities with a Web browser front-end and a relational database
`
`management system (RDBMS) containing site content and user data.
`
`8.
`
`I have authored five computer science textbooks in total, including
`
`Database Backed Websites (Macmillan), Software Engineering for Internet
`
`Applications, and an SQL language tutorial.
`
`9.
`
`I have served as an independent member of various advisory and
`
`corporate boards, mostly for technology companies. For example, I joined the
`
`corporate board of an MIT materials science spin-off in late 2005 during a
`
`$550,000 seed capital phase. I stepped down when the company secured $10
`
`million in venture capital in mid-2007.
`
`10.
`
`I began working full-time as a computer programmer in 1978,
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`developing a database management system for the Pioneer Venus Orbiter at the
`
`
`
`National Aeronautics and Space Administration’s Goddard Space Flight Center.
`
`11.
`
`In the early 1980s I developed computer-aided design software for
`
`electronic systems, specifically to assist digital hardware engineers designing
`
`processors at Hewlett-Packard and Symbolics. The integrated circuit design
`
`software that I built at Symbolics included the capability to automatically
`
`configure various kinds of circuits.
`
`12.
`
`I co-developed a computer program for computer-aided design of
`
`mechanical systems in the mid-1980s. This was called the ICAD System. The
`
`ICAD System enabled engineers to decompose a mechanical design into a
`
`hierarchy of subassemblies and establish configuration rules at each level of
`
`subassembly. The end-result was a system in which it was possible to go from
`
`customer specifications to a finished design without human intervention. The first
`
`applications for the ICAD System involved large structures built from steel, such
`
`as house-sized air-cooled heat-exchangers used in commercial buildings and
`
`industrial plants.
`
`13.
`
`ICAD went public as “Concentra” in the 1990s and was acquired by
`
`Oracle Corporation in 2002. The product’s mechanical design capabilities were
`
`deemphasized and its configuration capabilities were improved for use as a
`
`general-purpose sales configuration system. The product survives today as Oracle
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`Configurator, part of the Oracle Applications suite of business software.
`
`
`
`“Understanding the ICAD System” is a 1990 marketing brochure that contains an
`
`explanation of some of the basic capabilities. Excerpts from this brochure are
`
`reproduced below:
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`
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`
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`(Ex. 1215 [ICAD] at 4-29 – 4-31, pages 80-82.)
`
`
`
`14.
`
`In the second half of the 1980s, I was the principal developer of a
`
`computer program for computer-aided design and control of civil engineering
`
`projects, specifically earthmoving. This work was the foundation of my master’s
`
`thesis at MIT and also of U.S. Patent Nos. 5,150,310 and 5,964,298, on which I am
`
`a named inventor.
`
`15.
`
`I developed my first program using a relational database management
`
`system in 1994. It was a Web interface to the Children’s Hospital Oracle RDBMS,
`
`Version 6. This application enabled doctors at the hospital to view patient clinical
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`data using any computer equipped with a Web browser.
`
`16.
`
`In 1995, I led an effort by Hearst Corporation to set up an
`
`infrastructure for Internet applications across all of their newspaper, magazine,
`
`radio, and television properties. This infrastructure included software for
`
`managing users, shopping carts, electronic commerce, advertising, and user
`
`tracking.
`
`17. Between 1995 and 1997, I significantly expanded the photo.net online
`
`community that I had started in 1993 to help people teach each other to become
`
`better photographers. I began distributing the source code behind photo.net to
`
`other programmers as a free open-source toolkit, called “ArsDigita Community
`
`System.” The toolkit was adopted by approximately 10,000 web sites worldwide.
`
`18.
`
`In May 1997, Macmillan published my first textbook on Internet
`
`Application development, Database-Backed Websites. A September 1998 update
`
`to this book was published as Philip and Alex’s Guide to Web Publishing
`
`(hardcopy version published in April 1999).
`
`19.
`
`In 1997, I started a company, ArsDigita, to provide support and
`
`service for the ArsDigita Community System. Between 1997 and the middle of
`
`2000, I managed the growth of ArsDigita to 80 people, almost all programmers,
`
`and $20 million per year in annual revenue. This involved supervising dozens of
`
`software development projects, nearly all of which were Internet Applications with
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`a Web front-end and an Oracle RDBMS back-end.
`
`20.
`
`In 1999, I supervised the packaging up of much of our ecommerce-
`
`related code into the “ecommerce” module of the ArsDigita Community System.
`
`As the founder, CEO, and chief technical employee of the company, I personally
`
`developed functional specifications, SQL data models (Structured Query
`
`Language, or “SQL”, the standard programming language for relational database
`
`management systems), and Web page flows that determined the user experience.
`
`21. Between 2000 and the present, I have managed software development
`
`projects for philip.greenspun.com and photo.net. Both online services are
`
`implemented as relational database management applications. In addition, I
`
`participated in developing postclipper.com, a Facebook application that allows
`
`parents to create electronic baby books from a subset of their Facebook postings.
`
`22. Separately from this commercial and public work, I have been
`
`involved as a part-time teacher within the MIT Department of Electrical
`
`Engineering and Computer Science, educating students in how to develop Internet
`
`Applications with an RDBMS back-end. In the spring of 1999, I taught 6.916,
`
`Software Engineering of Innovative Web Services, with Professors Hal Abelson
`
`and Michael Dertouzos. In the spring of 2002, this course was adopted into the
`
`standard MIT curriculum as 6.171. I wrote 15 chapters of a new textbook for this
`
`class, Software Engineering for Internet Applications. This book was published on
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`the Web at http://philip.greenspun.com/seia/ starting in 2002 and 2003 and also in
`
`
`
`hardcopy from MIT Press in 2006. I am the sole author of a supplementary
`
`textbook for the class, SQL for Web Nerds, a succinct SQL programming language
`
`tutorial available only on the Web at http://philip.greenspun.com/sql/. I use this
`
`book when I teach an intensive course in database programming at MIT, as I did
`
`most recently in January 2015.
`
`23. Based at least on my education and experience, I consider myself to
`
`be an expert in software engineering, including the development of configuration
`
`systems such as the system described in the ‘057 Patent.
`
`II. Relevant Legal Standards
`
`24.
`
`I have been asked to provide opinions regarding the validity of claims
`
`of the ‘057 Patent in light of the prior art.
`
`25.
`
`It is my understanding that a claimed invention is unpatentable under
`
`35 USC § 102 if a prior art reference teaches every element of the claim. This is
`
`sometimes referred to as “anticipation.”
`
`26.
`
`It is my understanding that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the alleged
`
`invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains. This is sometimes described as “obviousness.” I understand that
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`an obviousness analysis takes into account the level of ordinary skill in the art, the
`
`
`
`scope and content of the prior art, and the differences between the prior art and the
`
`claimed subject matter.
`
`27.
`
`It is my understanding that the Supreme Court, in KSR Int’l Co. v.
`
`Teleflex Inc., 550 U.S. 398 (2007) and other cases, has recognized several
`
`rationales for combining references or modifying a reference to show obviousness
`
`of the claimed subject matter. Some of these rationales include the following:
`
`combining prior art elements according to known methods to yield predictable
`
`results; simple substitution of one known element for another to obtain predictable
`
`results; a predictable use of prior art elements according to their established
`
`functions; applying a known technique to a known device to yield predictable
`
`results; choosing from a finite number of identified, predictable solutions, with a
`
`reasonable expectation of success; and some teaching, suggestion, or motivation in
`
`the prior art that would have led one of ordinary skill to modify the prior art
`
`reference or to combine prior art reference teachings to arrive at the claimed
`
`invention.
`
`III. Level of Ordinary Skill in the Art
`
`28.
`
`I have reviewed the ‘057 Patent, as well as the pertinent prior art
`
`documents discussed below. Based on this review and my knowledge of the
`
`configuration system field, including my work on ICAD system in the 1980s, it is
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`my opinion that a person having ordinary skill in the art would have the following:
`
`
`
`(1) a bachelor’s degree in computer science, electrical engineering, computer
`
`engineering, or similar technical field, or (2) equivalent experience in the design or
`
`implementation of configuration systems. The relevant field of art is product
`
`configuration software.
`
`29.
`
`I understand that this determination is made at the time of the
`
`invention, which I understand that the patentee states as being the October 4, 2004
`
`filing of U.S. Application No. 10/957,919, which ultimately issued as the ‘057
`
`Patent.
`
`30. As I also discussed
`
`in my “Qualifications and Professional
`
`Experience” section above, I am familiar with the level of knowledge and the
`
`abilities of a person having ordinary skill in the art at the time of the claimed
`
`invention based on my education and work experience.
`
`IV. The ‘057 Patent
`
`31. The ‘057 Patent discloses a configuration system and method for
`
`“processing complex configuration problems using configuration sub-models.”
`
`(Ex. 1201 [‘057 Patent] at 1:8-10.)
`
`32.
`
`In the Background of the Invention, the ‘057 Patent discloses a
`
`conventional product configuration process known in the prior art:
`
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`Patent No. 7,882,057
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`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`In one embodiment of a conventional
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`inference procedure,
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`configuration query 102 is formulated based on user configuration
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`input, a configuration engine performs the configuration query 102
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`using a configuration model 104, and the configuration engine
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`provides an answer 106 to the configuration query 102 based on the
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`configuration query 102 and the contents of the configuration model
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`104. The answer 106 represents a particular response to the
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`configuration query 102.
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`(Ex. 1201 [‘057 Patent] at 1:16-25.)
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`(Ex. 1201 [‘057 Patent] at Figure 1.)
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`33. The ‘057 Patent further discloses that relationships among features or
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`parts are recorded in a configuration model of a product, which can then be
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`queried:
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`Patent No. 7,882,057
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`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`A configuration model 104 uses, for example, data, rules, and/or
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`constraints
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`(collectively referred
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`to as "data")
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`to define
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`compatibility relationships between parts
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`(also commonly
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`referred to as "features") contained in a specific type of product.
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`A part represents a single component or attribute from a larger, more
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`complex system. Parts may be combined in different ways in
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`accordance with rules and/or constraints to define different instances
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`of the more complex system. For example, "V6 engine" or the exterior
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`color "red" can be parts on a vehicle, and a specific hard disk drive
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`can be a part on a computer. A part group, also called a group,
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`represents a collection of related parts. For example, an "Engines"
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`group might contain the parts "V6 engine" and "4 cylinder engine". A
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`product configuration is a set of parts that define a product. For
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`example, a vehicle configuration containing the parts "V6 engine" and
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`"red" represents a physical vehicle that has a red exterior and a V6
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`engine. A product can be a physical product such as a vehicle,
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`computer, or any other product that consists of a number of
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`configurable features such as an insurance product. Additionally, a
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`product can also represent a service. A configuration query (also
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`referred to as a "query") is essentially a question that is asked
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`about the parts and relationships in a configuration model. The
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`answer returned from a configuration query will depend on the
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`data in the configuration model, the approach used for answering
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`the question, and the specifics of the question itself. For example,
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`one possible configuration query, translated to an English sentence, is
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`the following: For the given configuration model, are the parts "red"
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`and "V6 engine" compatible with each other.
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`Patent No. 7,882,057
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`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`(Ex. 1201 [‘057 Patent] at 1:26-54, emphasis added.)
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`34. The ‘057 Patent describes
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`that, at
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`least with a monolithic
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`configuration model, the achievable complexity of configuration models has been
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`limited because of computer processing limitations:
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`Solving configuration problems using computer assisted
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`technology often requires a significant amount of data processing
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`capabilities. Consequently,
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`configuration
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`technologies
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`have
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`attempted to exploit increased data processing capabilities, memory
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`capacities, and network data transfer throughput rates by increasing
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`the capabilities of the configuration engines and/or enhancing the
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`complexity of configuration models and configuration queries. The
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`complexity of a configuration model can be defined in any number of
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`ways, such as by the diversity of parts, part groups, rules, and
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`constraints supported by the configuration model, by the number of
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`parts, rules, and constraints, and by the complexity of part and part
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`group relationships defined by configuration rules and constraints. In
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`any event, the practical complexity achievable for configuration
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`models has been limited by the ability of computer systems to
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`process data within a given period of time, T, and/or limited by
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`other processing constraints, such as a lack of memory. The time
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`period, T, represents an amount of time considered reasonable to
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`perform a configuration task. Time T can vary depending upon the
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`application and expectation of configuration system users.
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`(Ex. 1201 [‘057 Patent] at 2:37-57, emphasis added.)
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`35. Figure 3 of the ‘057 Patent illustrates limitations on configuration
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`Patent No. 7,882,057
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`models/configuration queries because of limited data processing capabilities, when
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`using prior art techniques that were known to the inventors. As complexity goes
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`up, shown from left-to-right on the x-axis of the graphic in Figure 3 (and
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`specifically depicted in line 302), the maximum data processing capability is
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`reached (depicted by dashed line 304). Thus, the graphic in Figure 3 indicates that
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`there is sufficient data processing capability to process the configuration model
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`represented as “A” (below dashed line 304), but insufficient data processing
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`capability to process the configuration model represented as “B” (above dashed
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`line 304).
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`(Ex. 1201 [‘057 Patent] at Fig. 3.)
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`36. To overcome the limitations imposed by data processing capabilities
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`Patent No. 7,882,057
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`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`on at least some prior art systems, the ‘057 Patent discloses:
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`A configuration model dividing and configuration sub-model
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`inference processing system and procedure addresses the issue of
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`configuration model and query complexity by breaking a
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`configuration problem down into a set of smaller problems,
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`solving them individually and recombining the results into a
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`single result that is equivalent to a conventional inference
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`procedure. In one embodiment, a configuration model is divided into
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`configuration sub-models that can respectively be processed using
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`existing data processing
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`resources. The sub-model
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`inference
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`procedure does not change the exponential nature of configuration
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`model and query complexity but instead generates configuration sub-
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`models on the side of the achievable performance curve. Accordingly,
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`a sub-model inference procedure provides a way to scale queries to
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`larger and more complicated configuration models. Embodiments of
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`the configuration model dividing and configuration sub-model
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`processing system and inference procedure allows processing by a
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`data processing system of configuration models and queries whose
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`collective complexity exceeds
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`the complexity of otherwise
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`unprocessable conventional, consolidated configuration models and
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`queries.
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`(Ex. 1201 [‘057 Patent] at 4:18-40, emphasis added.)
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`37. The ‘057 Patent discusses an embodiment where a consolidated
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`configuration model is divided into several sub-models.
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`Patent No. 7,882,057
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`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`FIG. 4 depicts the configuration model dividing and configuration
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`sub-model inference processing system 400 (referred to herein as
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`"sub-model processing system 400") that performs configuration
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`model dividing and configuration sub-model inference procedure 402
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`(referred to herein as "sub-model inference procedure 402"). The sub-
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`model inference procedure 402 includes operations 404, 406, 408, and
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`410. The sub-model processing system 400 can include software code
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`that is executable by a processor of a computer system, such as a
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`server computer system. In a network environment, the sub-model
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`processing system 400 can be accessed by and communicates with
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`any number client systems 401(1) through 401(n).
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`Operation 404 receives, as an input, a conventional, consolidated
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`configuration model 412 and divides the consolidated configuration
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`model 412 into a set of configuration sub-models CM1 through CMn,
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`where n is an integer representing the number of configuration sub-
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`models. The configuration sub-models are an input to this process. In
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`one embodiment, the configuration sub-models meet the following
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`criteria: a. Each configuration sub-model should represent a portion of
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`the source configuration model 412; b. The data collectively contained
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`in the configuration sub-models should be sufficient to provide an
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`answer for each of the sub-queries Q1 through Qn or query being
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`processed; and c. The configuration sub-models should be divided in
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`such a way that the results of the sub-queries or query can be
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`recombined to provide an answer to the input configuration query
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`414.
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`(Ex. 1201 [‘057 Patent] at 4:40-5:4.)
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`Patent No. 7,882,057
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`
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`Case No.: IPR2017-00151
`Attorney Docket No.: FPGP0129IPR3
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`(Ex. 1201 [‘057 Patent] at Fig. 4