Patent 0220967

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

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Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

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As previously established in the "Patent Summary" and "Prior Art" sections, "US patent 0220967" does not correspond to a granted US patent. Instead, it refers to US Patent Application Publication No. 2004/0220967 A1. Under 35 U.S.C. § 103, an invention is considered obvious if the differences between the claimed invention and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art (POSITA).

A definitive obviousness analysis under 35 U.S.C. § 103 for US Patent Application Publication No. 2004/0220967 A1 is not possible at this time. This is because a robust analysis requires:

  1. The full text of the claims: The precise language of the claims defines the metes and bounds of the invention and is essential for identifying the differences between the claimed invention and the prior art.
  2. Specific prior art references: While general categories of relevant prior art can be identified from the abstract, a concrete analysis demands knowledge of the specific documents (e.g., patents, publications) cited by the applicant or examiner, as well as any other relevant prior art that a patent search would uncover.

Without these critical components, it is not possible to:

  • Identify all the individual elements of each claim.
  • Precisely determine the differences, if any, between the claimed subject matter and the prior art.
  • Identify specific primary and secondary references to combine.
  • Articulate a clear and convincing "motivation to combine" those references, with a reasonable expectation of success, as required by Supreme Court precedent (e.g., KSR International Co. v. Teleflex Inc.).

Hypothetical Obviousness Framework (Based on Abstract and Title)

Assuming the claims of US 2004/0220967 A1 generally align with its abstract and title ("System and method for navigating a hierarchical data structure" involving displaying limited levels, expanding/collapsing, and searching/filtering), a hypothetical obviousness analysis might proceed as follows:

A Person Having Ordinary Skill in the Art (POSITA) in software development or user interface design, around the filing date of April 29, 2003, would have been familiar with:

  1. Primary Reference - Existing Graphical User Interfaces (GUIs) for Hierarchical Data: Prior art depicting basic file system browsers (e.g., Windows Explorer, macOS Finder, various Unix/Linux file managers) or tree-view controls commonly found in software applications. These systems inherently involve displaying hierarchical data and allowing user interaction to navigate.

    • Such a reference would show the fundamental concept of a hierarchical data structure and a visual representation of it.
  2. Secondary Reference(s) - Techniques for Managing Display Complexity and Enhancing Navigation:

    • Limited Level Display and Expand/Collapse Functionality: Many existing GUI components (e.g., tree views in toolkits like MFC, Swing, or web frameworks) already incorporated the ability to show only a limited number of levels by default and allow users to expand or collapse nodes. This was a common solution to "information overload" in deep hierarchies. A POSITA would have known to apply this technique.
    • Search and Filtering Features: Integrating search and filtering capabilities into data views was a well-known concept in software design. Most operating systems included file search functionality, and database interfaces commonly offered filtering options. A POSITA would have been motivated to combine a search/filter function with any data display to improve user efficiency and findability, especially within large or complex hierarchies.

Motivation for Combination:

A POSITA would have been motivated to combine these elements to improve the user experience and efficiency of navigating hierarchical data structures. The motivation would stem from well-known design principles prevalent in the early 2000s, such as:

  • Improving usability: Reducing "information overload" by only showing relevant parts of the hierarchy at a time (motivation to combine tree view with expand/collapse).
  • Enhancing efficiency: Allowing users to quickly locate specific items within the hierarchy, rather than manual browsing (motivation to combine search/filter with hierarchical display).
  • Standardizing user interaction: Integrating commonly accepted UI paradigms (e.g., tree views, search boxes) into a cohesive system.
  • Modular design: These features were often implemented as separate, but combinable, modules or design patterns in software development.

Reasonable Expectation of Success:

A POSITA would have had a reasonable expectation of success in combining these elements because:

  • The individual components (tree views, expand/collapse, search/filter) were well-understood and widely implemented in various software contexts.
  • The integration of these features did not present any unusual technical challenges. Software developers regularly combined such standard UI components to create more functional applications.

Conclusion on Obviousness (Hypothetical):

Based on the general description, if the claims of US 2004/0220967 A1 primarily cover merely displaying a portion of a hierarchical data structure, allowing expansion/collapse, and incorporating search/filter, then such an invention could be susceptible to an obviousness challenge by combining widely known and implemented GUI and data management techniques from the early 2000s. The motivation would be to improve user experience and efficiency in navigating hierarchical data, and the combination would involve known elements with a predictable outcome.

However, this remains a hypothetical analysis. A definitive determination requires the actual claims and identified prior art references.

Generated 6/1/2026, 12:48:31 AM