Obviousness

Obviousness Analysis for US Patent 10,783,192 under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would likely render claims of US Patent 10,783,192 (the '192 patent) obvious to a person having ordinary skill in the art (PHOSITA) at the time of the invention, and explains the motivation for such combinations. The '192 patent generally concerns a system and method for generating multi-document summaries from search results, incorporating user interface elements for refinement.

Legal Standard for Obviousness (35 U.S.C. § 103):
A patent claim is unpatentable if "the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains." This analysis considers:

1. The scope and content of the prior art.
2. The differences between the prior art and the claims at issue.
3. The level of ordinary skill in the pertinent art.
4. Secondary considerations of non-obviousness (not explicitly addressed in this section, but typically include commercial success, long-felt but unsolved needs, failure of others, etc.).

Level of Ordinary Skill in the Art:
A PHOSITA in this field would likely have a strong background in computer science, natural language processing (NLP), information retrieval, and user interface design. They would be familiar with search engine technologies, document summarization techniques (both single and multi-document), and principles of effective human-computer interaction.

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Combination 1: US 7,028,029 B2 (IBM) in view of US 2006/0064411 A1

• US 7,028,029 B2 (IBM) - "Methods, systems, and computer program products for providing search results summaries from multiple search services": This patent is highly relevant as it explicitly teaches a system for obtaining search results from multiple search services and generating a composite summary from these results. It describes a "meta-search" approach combined with summarization, directly addressing the multi-document summarization aspect of the '192 patent.

• US 2006/0064411 A1 - "Method and system for providing a search query result as a summary": This application further reinforces the concept of generating a summary from search results, emphasizing the creation of a concise and readable summary that synthesizes information from various sources.

• Motivation for Combination: A PHOSITA would be motivated to combine the teachings of the '029 patent and the '411 application to enhance the utility and user experience of search engines. The '029 patent clearly establishes the benefit of multi-document summarization for search results. The '411 application further elaborates on the importance of creating concise and readable summaries. It would be an obvious design choice to implement the summarization techniques described in '411 A1 within the multi-source search and summarization framework of '029 B2 to provide a more refined and user-friendly summarized output. Both aim to efficiently deliver synthesized information from multiple documents in response to a query. The combination would lead to a system that not only gathers results from diverse search services but also processes them to produce a high-quality, synthesized summary as described in '411 A1.

• Anticipated Elements (from '192 patent claims): This combination would likely render obvious claims related to:

  • Receiving a search query.
  • Obtaining search results from multiple documents.
  • Generating a multi-document summary from these results.
  • The general concept of a "system core" or equivalent for managing the flow between search and summarization components.

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Combination 2: US 7,028,029 B2 (IBM) or US 2006/0064411 A1 in view of US 2007/0150493 A1 (Microsoft)

• US 7,028,029 B2 (IBM) or US 2006/0064411 A1: As discussed above, these references teach the core concept of multi-document summarization of search results.

• US 2007/0150493 A1 (Microsoft) - "Generating query-biased summaries of search results": This application focuses on generating summaries specifically tailored to the user's query ("query-biased summaries"). It describes techniques for identifying and extracting sentences and passages from search result documents that are most relevant to the query's intent.

• Motivation for Combination: A PHOSITA would be motivated to combine the multi-document summarization systems of '029 B2 or '411 A1 with the query-biased summarization techniques of '493 A1. It is a well-known goal in information retrieval to provide users with the most relevant information. Having a system that not only summarizes multiple documents but also prioritizes information highly relevant to the specific query (as taught by '493 A1) would be a natural and obvious improvement to deliver more accurate and useful summaries. The '493 A1 publication directly addresses how to make summaries more effective by biasing them towards the user's query, which would be a desirable feature for any multi-document summarization system.

• Anticipated Elements (from '192 patent claims): This combination would likely render obvious claims related to:

  • Generating a multi-document summary.
  • Using the user's query to focus the summary on a particular topic.
  • Identifying key concepts or text fragments based on relevance to the query.

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Combination 3: US 7,716,218 B2 (Yahoo!) in view of US 7,028,029 B2 (IBM) or US 2006/0064411 A1

• US 7,716,218 B2 (Yahoo!) - "System and method for generating a topical summary of a search result set": This patent describes generating "topical summaries" from a set of search results, organized by topics and sub-topics.

• US 7,028,029 B2 (IBM) or US 2006/0064411 A1: These references teach the fundamental concept of multi-document summarization from search results.

• Motivation for Combination: A PHOSITA would be motivated to combine the topical organization of summaries from '218 B2 with the multi-document summarization capabilities of '029 B2 or '411 A1. While the '192 patent describes a "list of sentences" or "list of semantic concepts" for its summary presentation, the '218 B2 patent offers a structured way to present such a summary, which would naturally enhance user understanding and navigation of complex information sets. Organizing a multi-document summary by topics would be an obvious improvement to make the summary more digestible and useful, particularly when dealing with a large number of diverse search results. The goal is to present information clearly and efficiently, and topical organization is a well-known method for achieving this.

• Anticipated Elements (from '192 patent claims): This combination would likely render obvious claims related to:

  • Presenting the summary in various formats (e.g., list of semantic concepts, cluster hierarchy).
  • Extracting key semantic concepts from documents and organizing them in the summary.

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Specific User Interface Elements and Motivation for Combination with General Multi-Document Summarization:

The '192 patent also includes specific user interface elements, such as:

• A summary request button (FIG. 1, 100).
• A text fragments field to specify the number of sentences (FIG. 1, 105).
• Checkboxes to select/deselect search results for summarization (FIG. 1, 110).
• Options to hide/show sources and group sentences per source (FIG. 2, 223, 225, 227).
• Ability to regenerate summaries based on user modifications (FIG. 2, 215).

While the prior art references discussed above establish the core multi-document summarization concepts, a PHOSITA would have been motivated to combine these with conventional user interface design principles to create a more interactive and customizable search experience.

• Motivation: Given the existence of multi-document summarization (e.g., '029 B2, '411 A1) and query-biased summarization ('493 A1), a PHOSITA would naturally seek to provide users with control over the summary generation process. It is a common design goal in software applications to allow users to customize outputs.
  • Summary Request Button: The idea of a button to initiate an action (like "Get text summary of results!") is a fundamental and ubiquitous GUI element. Placing such a button on a search results page (as shown in FIG. 1) would be a straightforward design choice to trigger the known summarization function.
  • Specifying Summary Length (Text Fragments Field): Providing a numerical input field (e.g., "text fragments field 105") for users to define the length of a generated summary is a common user preference setting in document processing and summarization tools. It would be obvious to a PHOSITA to offer this control, as different users have different needs for summary conciseness.
  • Selecting Sources for Summarization (Checkboxes): Allowing users to select which search results to include in a summary via checkboxes (e.g., "checkboxes 110") is a standard way to enable user filtering and customization of input sets. This would be an obvious way to empower users to refine the basis for their summary, especially in a multi-document context where not all initial results may be equally desirable.
  • Display Options (Hide/Show Sources, Group Sentences): Providing options to control the presentation of the summary, such as hiding or showing source references (e.g., "hide sources setting 223," "show sources setting 225") or grouping sentences by source (e.g., "group sentences per source setting 227"), would be obvious to a PHOSITA interested in improving the readability and utility of the summary display. These are common display preferences offered in many content presentation applications.
  • Regenerating Summary: The ability to modify parameters and regenerate a summary (e.g., "modify summary button 215") is a logical extension of offering user controls. If users can change input or display preferences, the system must logically be able to re-process and re-display the output accordingly.

Therefore, while the specific combination of all these UI elements might represent a particular implementation, each element, when considered in the context of the established prior art for multi-document summarization and general UI design principles, would likely be deemed obvious to a PHOSITA. The motivation would be to provide a more flexible, user-centric, and interactive summarization tool for search results.