Petition for Inter Partes Review of U.S. Patent No. 7,945,860 UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD ServiceNow, Inc. Petitioner v. Hewlett‐Packard Company Patent Owner U.S. Patent No. 7,945,860 Filing Date: May 14, 2003 Issue Date: May 17, 2011 TITLE:SYSTEMS AND METHODS FOR MANAGING CONVERSATIONS BETWEEN INFORMATION TECHNOLOGY RESOURCES PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,945,860 Inter Partes Review No. 2015‐00716
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Petition for Inter Partes Review of U.S. Patent No. 7,945,860
UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE PATENT TRIAL AND APPEAL BOARD
ServiceNow, Inc. Petitioner
v.
Hewlett‐Packard Company Patent Owner
U.S. Patent No. 7,945,860 Filing Date: May 14, 2003 Issue Date: May 17, 2011
TITLE: SYSTEMS AND METHODS FOR MANAGING
CONVERSATIONS BETWEEN INFORMATION TECHNOLOGY RESOURCES
PETITION FOR INTER PARTES REVIEW
OF U.S. PATENT NO. 7,945,860
Inter Partes Review No. 2015‐00716
Table of Contents
Page
‐i‐
I. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1) .................................. 1
A. Real Party‐ln‐lnterest under 37 C.F.R. § 42.8(b)(1) ............................. 1
B. Related Matters under 37 C.F.R. § 42.8(b)(2) ..................................... 1
C. Lead and Back‐Up Counsel under 37 C.F.R. § 42.8(b)(3) .................... 1
D. Service Information ............................................................................ 2
E. Power of Attorney .............................................................................. 2
II. PAYMENT OF FEES ‐ 37 C.F.R. § 42.103 ........................................................ 2
III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R. §§ 42.104 AND 42.108 .................................................................................. 2
A. Grounds for Standing under 37 C.F.R. § 42.104(a) ............................. 2
B. Identification of Challenge under 37 C.F.R. § 42.104(b) and Statement of Precise Relief Requested .............................................. 3
C. Requirements for Inter Partes Review 37 C.F.R. § 42.108(c) .............. 4
IV. BRIEF BACKGROUND OF THE UNDERLYING TECHNOLOGY ........................... 5
A. Early History of Conducting Business over the Web ........................... 5
B. Modern “Web Services” ..................................................................... 6
V. SUMMARY OF THE CLAIMED SUBJECT MATTER ........................................... 7
A. The Specification of the ’860 Patent ................................................... 7
B. The Challenged Claims of the ’860 Patent .......................................... 9
VI. CLAIM CONSTRUCTION UNDER 37 C.F.R. § 42.104(B)(3) ............................ 11
A. “Web service” ................................................................................... 11
B. “conversation” .................................................................................. 12
C. “managed object” and “conversation managed object” ................. 12
VII. CLAIMS 1, 5, 7‐10, 12, 15 AND 24‐26 OF THE ’860 PATENT ARE UNPATENTABLE .......................................................................................... 20
A. Ground 1 – Claims 1 and 24 Are Obvious Over the Collaborate References in view of Fox ................................................................. 20
1. Prior Art and Date Qualification for Ground 1 ........................ 20
2. Brief Summary of the Prior Art Applied in Ground 1 .............. 22
3. The Collaborate References Are Properly Combinable .......... 25
a. “a computer processor” (Claim 1[a]) ............................ 29
b. "a conversation managed object executable on the computer processor" (Claim 1[b]) .......................... 30
c. “the conversation managed object includes at least one interface configured to provide management information about the conversation to at least one manager” (Claim 1[c]) .......................... 33
d. “the at least one interface is configured to provide information regarding the Web service that contains the conversation” (Claim 1[d]) ....................... 40
a. “conversation interface” limitations (Claims 24[a], 24[b]) ............................................................................ 43
i. “a conversation interface” (Claim 24[a]) ............ 43
Table of Contents (continued)
Page
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ii. “wherein the conversation interface includes information for monitoring messages in a conversation” (Claim 24[b]) ........ 45
iii. “…including at least one of the number of failed messages; the number of successful messages; the total number of messages; the last message received by a resource;” (Claim 24[b1]) ..................................................... 47
iv. “and; at least one of the identity of resources participating in the conversation; the number of resources participating in the conversation; an identifier of the conversation; and an identifier of the resource that contains the conversation interface.” (Claim 24[b2]) ................................... 49
b. “a managed object interface associated with the conversation interface” (Claim 24[b]) .......................... 50
B. Ground 2 – Claims 5, 7‐9, 12, 15 and 25 Are Obvious Over the Collaborate References in view of Fox and Staub ............................ 54
1007 Excerpts from David A. Chappell et al., Java Web Services (2002), pp. 1‐12
1008 Excerpts from David Fox et al., Web Publisher’s Construction Kit with HTML 3.2 (1996), pp.480‐544
1009 Excerpts from Kenn Scribner et al., Applied SOAP: Implementing .NET XML Web Services (2001), pp.10‐48
1010 Excerpts from Elliotte Rusty Harold et al., XML in a Nutshell (2001), pp. xi‐xvi, 3‐10
1011 BEA Unveils Comprehensive Web Services Strategy and Support For Widest Range of Web Services Standards in the Industry, PR Newswire, Feb. 26, 2001
1012 Microsoft Computer Dictionary (5th ed. 2002), pp.279‐80
1013 BEA and Gauss Interprise Announce Strategic Relationship, Canadian Corporate Newswire, Aug. 27, 2001
1014 Affidavit of Christopher Butler, dated January 15, 2015
1015 U.S. Patent No. 6,891,930 to David B. Staub et al.
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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Petitioner ServiceNow, Inc. (“Petitioner”) respectfully submits this Petition
for Inter Partes Review of claims 1, 5, 7‐10, 12, 15 and 24‐26 of U.S. Patent No.
7,945,860 [Ex. 1001] (“the ’860 patent”).
I. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1)
A. Real Party‐ln‐lnterest under 37 C.F.R. § 42.8(b)(1)
The Petitioner, ServiceNow, Inc. is the real party‐in‐interest.
B. Related Matters under 37 C.F.R. § 42.8(b)(2)
The ’860 patent is the subject of one pending litigation involving the
Petitioner: Hewlett‐Packard Company v. ServiceNow, Inc., Case No. 14‐CV‐00570
BLF (N.D. Cal. filed Feb. 6, 2014), in which the patent owner contends that the
Petitioner infringes the claims of the ’860 patent challenged in this Petition. The
Petitioner was served with the Complaint in that action on February 7, 2014.
C. Lead and Back‐Up Counsel under 37 C.F.R. § 42.8(b)(3)
Petitioner provides the following designation of counsel.
LEAD COUNSEL BACK‐UP COUNSEL
Heidi L. Keefe (Reg. No. 40,673) [email protected][email protected] COOLEY LLP ATTN: Patent Group 1299 Pennsylvania Ave., NW, Suite 700 Washington, DC 20004 Tel: (650) 843‐5001 Fax: (650) 849‐7400
Andrew C. Mace (Reg. No. 63,342) [email protected][email protected] COOLEY LLP ATTN: Patent Group 1299 Pennsylvania Ave., NW, Suite 700 Washington, DC 20004 Tel: (650) 843‐5808 Fax: (650) 849‐7400
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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D. Service Information
This Petition is being personally served at the current correspondence
address for the ’860 patent, HEWLETT‐PACKARD COMPANY, Intellectual Property
Administration, 3404 E. Harmony Rd., Mail Stop 35, Fort Collins, CO 80528. The
Petitioner may be served at the addresses provided above for lead and back‐up
counsel, and consents to electronic service at those addresses.
E. Power of Attorney
Filed concurrently with this Petition in accordance with 37 C.F.R. § 42.10(b).
II. PAYMENT OF FEES ‐ 37 C.F.R. § 42.103
This Petition requests review of eleven (11) claims of the ’860 patent.
Accordingly, a payment of $23,000 is submitted herewith. This payment is
calculated based on a $9,000 request fee (for up to 20 claims), and a post‐
institution fee of $14,000 (for up to 15 claims). See 37 C.F.R. § 42.15(a). This
Petition meets the fee requirements of 35 U.S.C. § 312(a)(1).
III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R. §§ 42.104 AND 42.108
A. Grounds for Standing under 37 C.F.R. § 42.104(a)
The Petitioner certifies that the ’860 patent is available for inter partes
review and that the Petitioner is not barred or otherwise estopped from
requesting inter partes review on the grounds identified in the present Petition.
The Petitioner is unaware of any previous petition for inter partes review with
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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respect to the ’860 patent.
B. Identification of Challenge under 37 C.F.R. § 42.104(b) and Statement of Precise Relief Requested
The Petitioner respectfully requests that the Board initiate inter partes
review of claims 1, 5, 7‐10, 12, 15 and 24‐26 based on the following prior art:
agreements, messages sent).” (underlining added to both).)
These resource monitoring features are provided by the MBeans, the
claimed “conversation managed object.” The Collaborate References describe at
least six different MBeans that are associated with WebLogic Collaborate. (Id. at
2‐3, Table 2‐1.) For example, the MBean called “WLCMBean” is “[u]sed for
monitoring a WebLogic Collaborate instance at run time.” (Id. (first item in Table
2‐1; underlining added).) Another MBean described in the Collaborate
References, “DeliveryChannelMBean,” is “[u]sed for monitoring delivery
channels on WebLogic Collaborate at run time.” (Id. (second item in Table 2‐1).)
The other MBeans perform other management tasks for WebLogic
Collaborate such as monitoring trading partners, monitoring messages for
WebLogic Collaborate and so forth. (Id. at 2‐3 to 2‐4, Table 2‐1.) As noted
previously, the specification of the ’860 patent expressly lists “monitoring” as an
example of managing a resource. (’860, Ex. 1001, 5:1‐4.)
These MBeans, individually or as a group, clearly qualify as “an object for
managing a resource that is associated with a conversation.” The Collaborate
References therefore disclose “a conversation managed object executable on the
computer processor,” as recited in the claim.
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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c. “the conversation managed object includes at least one interface configured to provide management information about the conversation to at least one manager” (Claim 1[c])
The Collaborate References also disclose that the Managed Beans (the
“conversation managed object”) include “at least one interface configured to
provide management information about the conversation to at least one
manager.” Because the claimed “interface” provides management information to
a “manager,” this Petition will first address the “manager.”
The “manager” in the Collaborate References takes the form of an
Administration Console, a web‐based user interface that can be accessed by an
administrator using a web browser. (See Administering Collaborate, Ex. 1005, at
1‐8 to 1‐9, Figure 1‐1.) The Administration Console provides access to
management features of the Web service, i.e., WebLogic Collaborate:
You can use the WebLogic Collaborate Administration Console to:
added).) As discussed in detail above, one of ordinary skill in the art would have
had many motivations to combine. (Lavian Decl., Ex. 1002, ¶¶ 117‐120, 138, 139.)
ii. “wherein the conversation interface includes information for monitoring messages in a conversation” (Claim 24[b])
Both interfaces described above for the claimed “conversation interface,”
i.e. the MBeans API and the web server interface (such as CGI), include
“information for monitoring messages in a conversation.” With respect to the
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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MBeans APIs, as explained for claim 1[c] above, the Managed Beans or MBeans
provide information for monitoring messages in WebLogic Collaborate
conversations. For example, the MBeans can produce lists of conversations for
display in the WebLogic Collaborate Administration Console. (See Part VI.C.1
above; see also Administering Collaborate, Ex. 1005, at 6‐10 (under “Monitoring
Conversations”).) The getActiveConversations() method discussed above, for
example, will “return[] an array of type ConversationMBean that represents all
the active conversations in this session.” (Programming Collaborate, Ex. 1006 at
2‐10 (under “Step 6: Navigate Across MBeans”) (underlining added).) This lets the
user monitor a conversation using the Administration Console. (Administering
Collaborate, Ex. 1005, at 6‐11, Figure 6‐5 (“Monitoring a Conversation”).)
With respect to the second theory outlined above in which the claimed
“conversation interface” comprises a web server interface such as the Common
Gateway Interface (CGI), as explained in great detail for claim 1[d], an interface
such as CGI could also have included “information for monitoring messages in a
conversation.” This is because the conversation monitoring information is
reported back to the user through a web page accessible through the
Administration Console, as explained above. (Administering Collaborate, Ex.
1005, at 6‐11, Figure 6‐5 (“Monitoring a Conversation”).)
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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The web server interface would have included “information for monitoring
messages in a conversation” because, as noted previously, that interface was
used to obtain and deliver the web page for the Administrative Console showing
the monitoring information. (Fox, Ex. 1008, at 490 (under “Lesson #4: How to Use
a Script to Access Other Applications”).) As explained previously, one of ordinary
skill in the art would have had ample motivation to combine the Collaborate
References with Fox. Therefore, the Collaborate References alone, or in
combination with Fox, disclose that the conversation interface “includes
information for monitoring messages in a conversation.”
iii. “…including at least one of the number of failed messages; the number of successful messages; the total number of messages; the last message received by a resource;” (Claim 24[b1])
Claim 24[b1] continues by requiring that the “information for monitoring
messages in a conversation” include “at least one of” several pieces of
information including “the last message received by a resource” and “the total
number of messages.” The Collaborate References disclose both of these.
In particular, the Collaborate References disclose message information for
various WebLogic Collaborate resources, including a trading partner session or
WebLogic runtime instance. (Administering Collaborate, Ex. 1005, at 6‐4 to 6‐5
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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(Table 6‐1).) For example, the system maintains, for a trading partner session,
“time of last sent and received message” and “number of messages sent.” (Id. at
6‐4 (in “Trading partner page,” “Sessions” column, second bullet point); id.
(showing same information for WebLogic instance).) Figure 6‐4 shows this
information to a user through a web page in Administration Console:
(Administering Collaborate, Ex. 1005 at 6‐8.)
The screen above shows (among other things) the total number of
messages and the date and time of the last message received. Another figure
(Figure 6‐2) lists the number of “Messages Sent” and “Messages Received,”
further disclosing a total message count. (Id. at 6‐2 (Fig. 6‐2 (“Server Statistics”).)
It would have been known and obvious to one of ordinary skill that the MBeans
APIs (the “conversation interface”) provide this monitoring information to the
Administration Console. (See Programming Collaborate, Ex. 1006, at 2‐2 (“The
WebLogic Collaborate Administration Console tools also use these APIs to provide
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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real‐time monitoring information.”) (under “MBeans and the MBean Server”).)
This limitation would also have been trivially obvious to a person of
ordinary skill in the art. As explained by Dr. Lavian, the count of successful, failed
and total messages, and information about the last message received, are basic
pieces of statistical information that any management system could have tracked,
for example, using basic server communication logs. (Lavian Decl. ¶¶ 154‐55.) A
person of ordinary skill in the art would have found this limitation obvious over
the teachings of Collaborate References.
iv. “and; at least one of the identity of resources participating in the conversation; the number of resources participating in the conversation; an identifier of the conversation; and an identifier of the resource that contains the conversation interface.” (Claim 24[b2])
The monitoring information in claim 24[b2] could include “an identifier of
the conversation.” This is shown in Figure 6‐5 below
(Administering Collaborate, Ex. 1005 at 6‐11.)
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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The text following the label “Conversation:” provides “an identifier of the
conversation.” (Id. (“Identifying information, start time, self‐initiated indicator,
time of last message, and identity of last sender are displayed.”) (underlining
added).) It also shows “the identity of resources participating in the
conversation,” as recited in claim 24[b2]. This is shown in the “Last Sender:” field,
which identifies the trading partner that sent the last message to the
conversation. The Collaborate References therefore disclose claim 24[b2].
b. “a managed object interface associated with the conversation interface” (Claim 24[b])
The second limitation of claim 24 recites “a managed object interface
associated with the conversation interface.” There is no further mention of this
interface in claim 24. The claim does not expressly recite any particular function
this interface must perform, it simply requires that it exist.
The Collaborate References disclose this limitation. As noted in Part VI.E.2
above, a “managed object interface” is an “interface associated with a managed
object (i.e., an object for managing a resource).” For purposes of claim 24, the
“managed object” takes the form of a repository service that manages a
resource, e.g., configuration and other information for WebLogic Collaborate.
(Introducing Collaborate, Ex. 1004, at 1‐29 (“The repository service stores data
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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into the repository.”); Administering Collaborate, Ex. 1005, at 7‐1 (“The repository
is a database that stores configuration information for WebLogic Collaborate.”)
(under “Working with the Repository”).) The repository offers data importing and
exporting and other features through the Administration Console. (Introducing
Collaborate, Ex. 1004, at 1‐29 to 1‐30, 2‐19 to 2‐21.)
As with the “conversation interface” of this claim discussed above, there
are at least two ways in which the prior art discloses the claimed “managed object
interface.” First, the “managed object interface” takes the form of the interface
that facilitates the connection between the
repository services and the Administration
Console. The relationship between these
components is shown in Figure 1‐9 of
Introducing Collaborate at right. (Ex. 1004,
at 1‐29 (Figure 1‐9: “WebLogic Collaborate Services”).) As shown in Figure 1‐29,
the Repository Services (middle row) interface with the WebLogic Collaborate
Administration Console (top right) through the “Administration Services.” (Id. at
1‐28 (“WebLogic Collaborate system components are configured and managed
primarily through the WebLogic Collaborate Administration Console, which works
together with a repository service.”) (underlining added).) The presence of this
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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interface is further confirmed by the fact that the repository service is accessible
through Administration Console web pages. (Introducing Collaborate, Ex. 1004, at
1‐30.) The Collaborate references therefore disclose an “interface” associated
with the repository service.
The Collaborate References disclose that this “managed object interface” is
“associated with the conversation interface” under both of the theories outlined
above. In the case in which the “conversation interface” comprises the Managed
Beans or MBeans APIs, this association is clearly shown in Figure 1‐9 above. That
figure shows “Administrative Services” facilitating connection from the
Administration Console, for both the MBeans Server (which provides the MBeans
and their associated APIs) and the Repository Services. The repository service is
associated with the MBeans APIs that comprise the “conversation interface”
because, among other things, both interfaces work together to provide
management features for the WebLogic Collaborate Administration Console.
This managed object interface is also “associated with the conversation
interface” under the second theory in which the interface comprises a web server
interface such as CGI used to obtain conversation information. Under this theory,
the “managed object interface” is associated with the web server interface
because both interact with the WebLogic Collaborate Administration Console.
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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Second, although Collaborate References alone disclose the “managed
object interface,” this interface could also be found through the combination of
the Collaborate References and Fox. As have explained in great detail above, web
server interfaces such as CGI provide a mechanism for a web server to receive
input from a web browser through a web page (such as the Administration
Console), and interface with an external application to create a customized web
page in response to the user’s request. (Fox, Ex. 1008, at 484‐85.) It would have
been obvious to adapt the web server interface and CGI teachings of Fox to the
Collaborate References. (Lavian Decl. ¶¶ 168‐69.)
This would predictably have resulted in a system in which the
Administration Console used a web server interface such as CGI to access the
WebLogic Collaborate repository. Fox expressly discloses that one of the
purposes for which CGI is used is to “do database searches” (id. at 484), or “access
huge databases” (Fox, Ex. 1008, at 485). The WebLogic repository, as noted
above, comprises a database. (Administering Collaborate, Ex. 1005, at 7‐1 (“The
repository is a database that stores configuration information for WebLogic
Collaborate.”) (under “Working with the Repository”).)
One of ordinary skill in the art would have been motivated to use a web
server interface such as CGI to provide an interface for the managed object, i.e.
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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the WebLogic repository. (Lavian Decl., Ex. 1002, ¶ 170.) Finally, as noted above,
the managed object interface is “associated with the conversation interface”
because both interfaces work together to provide management features for the
Administration Console. For all of these reasons, claim 24 is obvious.
B. Ground 2 – Claims 5, 7‐9, 12, 15 and 25 Are Obvious Over the Collaborate References in view of Fox and Staub
Claims 5, 7‐9, 12, 15 and 25 depend from claims 1 or 24 and recite
providing additional types of statistical information about messages. They recite
the “last fault message returned from the conversation” (claim 5), “number of
successful messages processed by the conversation” (claim 7), and so forth.
These claims offer nothing non‐obvious over the Collaborate References
and Fox. As explained by Dr. Lavian, it would have been obvious to adapt the
claimed “interface” (claim 1) or “conversation interface” (claim 24) in the
Collaborate References to provide this information. This information represents
the type of basic statistics that management systems routinely maintained and
tracked. (Lavian Decl., Ex. 1002, ¶ 174.) This information could have been readily
derived, for example, from basic server communication logs that record sent and
received messages, and the success or failure of those messages. (Id.)
In fact, the Collaborate References state that “WebLogic Collaborate
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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provides a logging capability for error and information messages. All WebLogic
Collaborate log messages are time‐stamped, and can be sent to the WebLogic
Server log, or to a separate log file.” (Introducing Collaborate, Ex. 1004, at 1‐32
(under “Logging Service”) (underlining added).) The Collaborate References also
disclose providing failed message information such as the “time of first and last
failed message.” (Administering Collaborate, Ex. 1005 at 6‐4 (“Trading partner
page,” “Sessions,” second bullet point) (underlining added).)
It would have taken no stretch of a skilled artisan’s imagination to adapt
the claimed “interface” in WebLogic Collaborate to provide each of the specific
types of information recited in claims 5, 7‐9, 12, 15 and 25. (Lavian Decl., Ex.
1002, ¶ 177.) These additional features are also obvious in view of Staub [Ex.
1015], which discloses a technique for recording, processing and tallying network
errors and fault messages, as explained below. (Staub, Ex. 1015, 1:7‐9, 1:54‐61.)
1. Claims 5, 15 and 25 (“Fault Message” Claims)
These claims recite similar subject matter relating to “fault messages” and
will thus be addressed here. It would have been obvious to adapt the “interface”
of the Collaborate References to provide the fault message information in claims
5, 15 and 25. As noted, the references already disclose recording the “time of
first and last failed message.” (Administering Collaborate, Ex. 1005 at 6‐4.)
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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Moreover, Staub discloses a method and system for receiving, recording and
processing fault messages. “A system for cataloging and detecting network faults,
includes a communication interface for receiving a fault message from a
network.” (Staub, Ex. 1015, 1:54‐56 (underlining added).) The network fault is
parsed, and “[a]n associative database is connected to the parser and stores a
tally for the fault message.” (Id., 1:58‐59 (underlining added).) If the tally of
network faults exceeds a specific “threshold,” a problem message is sent to an
operator interface. (Id., 2:38‐39.)
As explained by Dr. Lavian, it would have been obvious to adapt Staub to
the Collaborate References, with no change in their respective functions,
predictably resulting in the claimed “interface” of WebLogic Collaborate providing
information about the “last fault message” (claim 5), an “unexpected fault
message” (claim 15) and that “a participant in the conversation sent a fault
message” (claim 25). (Lavian Decl. ¶ 184.)1 As noted above, the Collaborate
1 The Collaborate References clearly disclose that “the conversation is further
configured to receive messages,” as recited in claims 5, 7 and 8. (See Introducing
Collaborate, 1004, at 1‐7 to 1‐8 (a conversation “[i]s a series of business messages
exchanged between trading partners.”); Lavian Decl., Ex. 1002, ¶ 180.)
Petition for Inter Partes Review of U.S. Patent No. 7,945,860
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References already disclose an interface that provides information about the “last
failed” message, and expressly disclose features for logging error messages. One
of ordinary skill in the art would have found it trivial to add the ability to provide
information about fault messages as well. (Id. ¶ 185.) Fault messages are
common in any network, and persons of ordinary skill in the art used fault
messages to monitor network performance. (Id. ¶ 186.) Staub provides an
express motivation by explaining that “network devices generate error
messages,” and “[t]hese error messages help technicians repair the network
devices.” (Staub, Ex. 1015, 1:13‐15 (underlining added).) These claims are