Prior art

Analysis of Prior Art Cited in US Patent 6,266,674

This section details the prior art references cited during the examination of US Patent 6,266,674. Each reference is analyzed for its potential to anticipate the claims of the '674 patent under 35 U.S.C. § 102. For a reference to anticipate a claim, it must disclose, either expressly or inherently, each and every element of that claim.

U.S. Patent 4,651,289: Electronic Notebook

• Full Citation: US 4,651,289, "Electronic Notebook," issued to Morita, et al.
• Publication Date: March 17, 1987
• Filing Date: April 26, 1984
• Brief Description: This patent describes an "electronic notebook" that can store handwritten information, including characters and graphics, as stroke-sequence data. It allows for the creation of multiple "pages" of notes and the ability to retrieve these pages. A key feature is the ability to associate a representative mark or symbol with a page for easier identification and retrieval, acting as a form of index or "label."
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '289 patent discloses a method and apparatus for storing information (handwritten notes) and associating a "label" (a representative mark) with that information. Users can create and store this information in a structured way (pages in a notebook). This appears to teach the core elements of inputting information, designating a portion as a label, and storing it within a data structure.
  • Independent Claims 35 & 45 (Retrieving Information): The '289 patent describes retrieving stored pages by selecting their corresponding representative marks. This aligns with the concept of navigating a data structure, selecting a label, and retrieving the associated information. The structure in the '289 patent is a sequential or page-based one, rather than a user-defined hierarchy, which may represent a point of distinction.

U.S. Patent 4,866,638: Method of Storing and Retrieving Information in a Computer System

• Full Citation: US 4,866,638, "Method of Storing and Retrieving Information in a Computer System," issued to Cosentino.
• Publication Date: September 12, 1989
• Filing Date: August 26, 1986
• Brief Description: This patent details a system for organizing and retrieving text-based information. It uses a "card and stack" metaphor, where information is placed on virtual cards that are then organized into stacks. Users can label these cards and stacks, and the system provides a way to search for and retrieve information based on these labels.
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '638 patent discloses a method and apparatus for a user to input information, create labels for it ("card" and "stack" labels), and place these within a pre-defined, albeit simple, data structure. This could be argued to anticipate the broad steps of storing information and associating it with a user-defined label within a data structure.
  • Independent Claims 35 & 45 (Retrieving Information): The system in the '638 patent is designed for retrieval based on the created labels. A user can navigate through stacks and select cards to view the information. This maps closely to the elements of navigating a data structure and selecting a label to retrieve data. The structure, however, is more of a container model than the flexible, user-defined hierarchy described in the '674 patent.

U.S. Patent 4,914,624: System and Method for Manipulating and Retrieving Information

• Full Citation: US 4,914,624, "System and Method for Manipulating and Retrieving Information," issued to Dunshie, et al.
• Publication Date: April 3, 1990
• Filing Date: October 26, 1987
• Brief Description: This invention describes a data retrieval system where information is stored in "items" which can be linked together to form a network or web of information. Each item can have a title or "label." The system allows users to create these items, label them, and establish links between them, thereby creating a user-defined structure for navigating the information.
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '624 patent appears to disclose all the high-level steps of claim 1. A user inputs information to create an "item," gives it a label (title), and then places it within a user-defined data structure by creating links to other items.
  • Independent Claims 35 & 45 (Retrieving Information): The system is built around navigating this user-created network of linked items. A user selects an item (the "label") to view its associated information and can then follow links to other related items. This strongly corresponds to the elements of navigating a data structure via labels to retrieve information. The "network" or "web" structure is a form of a user-defined data structure, similar to the hierarchy mentioned in the '674 patent.

U.S. Patent 5,020,019: Document Retrieval System

• Full Citation: US 5,020,019, "Document Retrieval System," issued to Ogawa.
• Publication Date: May 28, 1991
• Filing Date: December 29, 1988
• Brief Description: This patent details a document retrieval system that uses keywords for finding relevant documents. A key aspect is a "keyword connection table" which stores relationships between keywords. The system can learn and update these relationships based on user feedback, effectively creating a structured network of keywords (labels) that point to documents (information).
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '019 patent describes a system where documents (information) are stored and associated with keywords (labels). While the user doesn't manually place the label in a structure, the system itself organizes these labels into a relational data structure (the keyword connection table). This could be interpreted as anticipating the broader claims.
  • Independent Claims 35 & 45 (Retrieving Information): A user retrieves information by inputting a keyword (a label). The system then uses its internal data structure of keyword relationships to find and present the relevant documents. This aligns with the general concept of using labels within a data structure to retrieve information, although the navigation is more query-based than manual traversal of a visible hierarchy.

Other Cited Patents

The following patents were also cited as prior art. Their relevance appears to be for more specific features or general background, and they are less likely to anticipate the broad independent claims of the '674 patent on their own, but they contribute to the overall state of the art at the time of the invention.

• U.S. Patent 4,881,262: Discloses a voice message system where messages can be stored and forwarded, with some basic organization capabilities.
• U.S. Patent 5,038,319: Describes a system for organizing and accessing voice messages, including features for reviewing and categorizing messages.
• U.S. Patent 5,063,529: Details a personal digital assistant (PDA) type device that can store various types of information and has a user interface for organizing and retrieving it.
• U.S. Patent 5,109,509: Pertains to a method for structuring and retrieving information in a database system, focusing on efficient data organization.
• U.S. Patent 5,146,439: Describes a digital audio recording and playback system, which includes methods for indexing and quickly accessing portions of the recorded audio.

In summary, several of the cited prior art references, particularly US 4,651,289, US 4,866,638, and US 4,914,624, disclose systems that embody the core concepts of the independent claims of US 6,266,674: storing information, associating it with user-defined labels, organizing these labels in a data structure, and using these labels to retrieve the information. The novelty of the '674 patent, as argued during its prosecution, likely resided in the specificity of a user-defined hierarchical structure and the particular methods of navigating and manipulating it. However, the fundamental concepts appear to be well-established in the prior art. This aligns with the later court finding that the patent was directed to an abstract idea, as these prior art documents demonstrate that organizing information with user-defined labels was a known and practiced concept in computer systems.