Obviousness

Obviousness Analysis under 35 U.S.C. § 103

A patent claim is unpatentable as obvious if, at the time of the invention, a person of ordinary skill in the art (PHOSITA) would have been motivated to combine prior art teachings, or to modify prior art without a combination, to arrive at the claimed invention with a reasonable expectation of success. This motivation to combine is a critical requirement that guards against hindsight reasoning. The mere existence of prior art elements is not sufficient; there must be a clear reason or rationale for a PHOSITA to combine those elements in the claimed manner.

The PTAB has identified the following prior art references in IPR2026-00287 as challenging claims 1-26 of US10867001:

• US20070185859 (Alberth et al.)
• US20070233682 (Srinivasan)
• EP1801826B1 (Google)

To establish obviousness of US10867001's claims, it must be demonstrated that a PHOSITA would have been motivated to combine these references to achieve the features claimed in US10867001, particularly the annotation and filtering of search results based on the presence or absence of search term elements in referenced and descendant webpages.

Potential Combination: Alberth et al. + Srinivasan + EP1801826B1

Alberth et al.

Without the full text of Alberth et al. (US20070185859), it is difficult to detail its specific teachings. However, given its use as prior art against a patent related to search result annotation and filtering, it likely pertains to search engines, information retrieval, or methods of presenting search results.

Srinivasan

Similarly, without the full text of Srinivasan (US20070233682), a detailed analysis of its contribution to an obviousness argument is limited. Publicly available information indicates various patents by individuals named Srinivasan in different technical fields, but none directly related to search result annotation for missing terms are readily apparent from the search snippets. For example, one Anand Srinivasan is listed as an inventor on patents related to aftertreatment systems, microfluidics, and memory systems. Another Srinivasan S. Muthuswamy is listed as an inventor on patents for network graph hotspot identification and fraud detection. A Sridhar Srinivasan is listed as an inventor on patents related to feedstock processing corrosion management and path-based layer stack connectivity checks. Given the IPR challenge, it is assumed that US20070233682 (Srinivasan) contains teachings relevant to search result presentation, content analysis, or user interfaces in the context of web searches.

EP1801826B1 (Google)

EP1801826B1, being a Google patent, is highly likely to address aspects of web search, search result ranking, presentation, or advertising, which are core to Google's business. This reference could potentially disclose methods for analyzing webpage content or for displaying additional information alongside search results.

Motivation to Combine

A PHOSITA in the field of Internet search engines, prior to the priority date of US10867001 (June 17, 2011), would have been motivated to improve the relevance and efficiency of search results for users. The problem addressed by US10867001—that users waste time clicking on search results where the referenced webpages (or their descendants) do not contain all the specified search terms—is a persistent challenge in search engine design.

• Motivation to combine Alberth et al. and EP1801826B1: If Alberth et al. and EP1801826B1 individually disclose methods for presenting search results and analyzing webpage content, a PHOSITA would be motivated to combine these to provide more informative search results. For instance, if Alberth et al. describes a generic framework for displaying search results and EP1801826B1 details methods for content analysis, a PHOSITA would naturally combine these to enhance the search result display with insights derived from content analysis. The motivation would be to provide users with a better understanding of the content of linked pages before clicking, thereby improving user experience and search efficiency.

• Motivation to incorporate Srinivasan (US20070233682): Assuming US20070233682 (Srinivasan) offers teachings related to dynamic content analysis, filtering, or user feedback in search contexts, a PHOSITA would be motivated to integrate these functionalities. For example, if Alberth et al. and EP1801826B1 provide basic annotation of content presence, and Srinivasan provides methods for more sophisticated analysis, such as identifying missing terms or terms in descendant pages, the combination would be driven by the desire to offer a more precise and comprehensive warning system to users. The problem of "wasted clicks" due to missing search terms is a clear motivator for such an integration.

Specifically, the motivation for a PHOSITA to combine these references to arrive at the invention of US10867001 would stem from:

1. Improving User Efficiency: The recognized problem of users clicking on irrelevant links that do not contain their specified search terms (as acknowledged in US10867001's background) would strongly motivate a PHOSITA to find ways to signal the content relevance before the user navigates to the page.
2. Leveraging Existing Technologies: Each of these prior art references, in their respective areas of search result presentation, content analysis, or user interaction, would represent building blocks for a PHOSITA. Combining them to create a more robust and informative search result display would be a logical step in the continuous improvement of search engine technology.
3. Predictable Solution: If the individual references teach aspects of analyzing webpage content and displaying information, combining them to indicate the presence or absence of search terms could be seen as a predictable solution to the known problem of users encountering irrelevant search results. The specific formats for annotation (e.g., text, colors, symbols) or filtering criteria would be within the purview of routine design choices for a PHOSITA seeking to implement such a system.

Therefore, if Alberth et al. and EP1801826B1 disclose elements related to presenting search results and analyzing webpage content, and Srinivasan (US20070233682) provides techniques for identifying the presence or absence of specific terms, a PHOSITA would have a clear motivation to combine these references. The goal would be to create a system that proactively informs users about the relevance of linked content by annotating search results with information regarding the presence or absence of search terms, including those in descendant webpages, and potentially offering filtering capabilities, as claimed in US10867001.