Prior art

Prior Art Analysis for U.S. Patent 6,546,397

As a senior patent analyst, a thorough review of the prior art cited during the prosecution of U.S. Patent 6,546,397 reveals several key references that the USPTO examiner considered. These references provide context for the state of the art at the time of the invention and help define the novel contributions claimed by the patent. Below is an analysis of the most relevant cited patents.

U.S. Patent 5,740,432: "Method of and system for dynamically creating and displaying a document on a browser"

• Full Citation: U.S. Patent 5,740,432, issued April 14, 1998.
• Assignee: International Business Machines Corporation (IBM).
• Filing Date: June 7, 1995.
• Brief Description: This patent describes a system where a user's browser sends a request to a server. The server, in response, executes a program to dynamically generate an HTML document that is then sent back to the browser for display. This process allows the content of the web page to be tailored in real-time based on user input or other conditions, rather than being a static, pre-written file.
• Potential Anticipation of Claims: This reference is relevant to the general concept of dynamically generating web pages. However, it differs from the invention of 6,546,397. The '432 patent focuses on a server-side generation process, where a program on the server creates the HTML. In contrast, the '397 patent describes a client-side, browser-based "build tool" where the user constructs the web page in a WYSIWYG environment, and the final output is a run-time file and database that generate the page on the end-user's browser. Therefore, while related, the '432 patent does not appear to anticipate the core claims of the '397 patent, particularly the browser-based build engine and the creation of a single run-time file for client-side execution.

U.S. Patent 5,838,906: "Reusable, extensible and nested HTML document objects"

• Full Citation: U.S. Patent 5,838,906, issued November 17, 1998.
• Assignee: Microsoft Corporation.
• Filing Date: October 24, 1995.
• Brief Description: The '906 patent discloses a method for creating web pages using object-oriented principles. It describes "HTML document objects" which are reusable components that can be nested within one another to build a complex page. These objects can have properties and methods, allowing for more structured and modular web page design. This patent was a key piece of prior art cited in the successful IPR proceedings against the '397 patent.
• Potential Anticipation of Claims: This reference is highly relevant. It teaches the concept of modular, object-based construction of web pages, which aligns with the '397 patent's description of a build engine creating a database of objects that are then rendered by a run-time engine. When combined with a reference teaching a WYSIWYG editor, the PTAB found it would have been obvious to create the system claimed in the '397 patent. While it may not anticipate every limitation of claim 1 on its own under § 102 (as it doesn't explicitly describe the entire build-tool-to-runtime-file process in a single, integrated system), its disclosure of creating structured, object-based web documents was a foundational element in the eventual invalidation of the '397 claims on obviousness grounds.

U.S. Patent 5,911,043: "Browser-based application development tool"

• Full Citation: U.S. Patent 5,911,043, issued June 8, 1999.
• Assignee: In-Common, LLC.
• Filing Date: July 23, 1997.
• Brief Description: This patent describes a tool for developing applications that run within a web browser. It details a system that allows a developer to use a browser interface to assemble application components and logic. The tool then generates the necessary code (like HTML and JavaScript) for the application to be deployed and executed by end-users in their own browsers.
• Potential Anticipation of Claims: This is a very strong prior art reference against the '397 patent. It explicitly describes a "browser-based" tool for "application development," which is conceptually very similar to the "browser based web site generation tool" of the '397 patent. The '043 patent's disclosure of using a browser to create another browser-based application reads directly on the core concept of claim 1. It teaches the use of a browser-based interface to generate a deliverable product (an application) that is then run by an end-user. This significantly overlaps with the '397 patent's claimed method of using a browser-based build tool to create a run-time file and database. It likely anticipates the central elements of claim 1.

U.S. Patent 6,031,985: "Framework for building platform-independent user interfaces"

• Full Citation: U.S. Patent 6,031,985, issued February 29, 2000.
• Assignee: Sun Microsystems, Inc.
• Filing Date: May 14, 1997.
• Brief Description: This patent, related to the Java programming language, describes a framework for building user interfaces that are independent of the underlying operating system. It focuses on providing a set of UI components (buttons, menus, etc.) that can be assembled by a developer to create an application. The framework then handles the rendering of these components on different platforms, ensuring a consistent look and feel.
• Potential Anticipation of Claims: This reference is relevant to the implementation details of the "build engine" and "user interface" described in the '397 patent. The '397 specification mentions Java as a potential language for the build engine (Col. 5, ln. 57). The '985 patent provides a detailed blueprint for how such a platform-independent build tool could be constructed using a component-based framework. While it doesn't describe the entire process of generating a web page in a single run-time file, it discloses a key enabling technology for creating the very type of build tool claimed in the '397 patent. It is therefore highly relevant for obviousness, though less likely to be a direct anticipation under § 102 of the entire claimed method.