Obviousness

Obviousness Analysis of US Patent 6,772,229 Under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would render the claims of U.S. Patent 6,772,229 obvious to a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention (prior art date of November 13, 2000). The motivation for combining these references is drawn directly from the patent's own background description.

Identified Prior Art

The U.S. Patent 6,772,229 (hereinafter "the '229 patent") describes the following as prior art:

1. Centripetal Method Groupware: Examples include IBM's Lotus Notes and Domino, Microsoft's Exchange and NetMeeting, Novell's GroupWise, and others. These systems require "group members to remember to go to a central area (a server) in order to retrieve and exchange data and information". They store collaborative value in a central repository, and members must actively go to this resource to get information. These systems typically support features like central storage of participant inputs, two-way links to peripheral devices, and the association of related information inputs (e.g., for threaded discussions), and selective access based on user permissions.
2. Narrowcasting Method: Examples include PointCast's Client and Server, Marimba's Castanet, Microsoft's NetShow, and listserve products. These systems use a "one-to-many communication" model where content sources are decided by the narrowcaster, and users must "tune-in" or attend the narrowcasted content without necessarily knowing if new or relevant information is present. List-servers also push content (emails) but generally do not use a database for threaded, scrollable records and send to all subscribers.
3. Explicitly Stated "Improvement" for Prior Art Systems: The '229 patent's background section itself states: "It would be an improvement to such a system [referring to prior art methods that require convergence] for appointments and reminders for appointments to be “pushed” to the group member's awareness via e-mail with a Web hyperlink to the videoconference, via a narrowcast of the appointment, or other technologies that drive the information outward to the group member". This describes a system that pushes notices via email with a hyperlink or via narrowcasting, selectively to relevant group members, and provides a direct channel to specific content (e.g., a videoconference).

Motivation for Combination

The '229 patent clearly articulates the problem with existing prior art methods: "Both the centripetal and narrowcasting approaches suffer from the disadvantage that group members have to report and remember to report to a central area for communication and collaboration". It further notes that these methods "have failed to anticipate problems associated with the information age, such as information glut and competition for attention".

The patent itself provides a direct motivation for a PHOSITA to combine existing technologies: to address the identified drawback of users having to actively seek out information. The explicitly stated "improvement" in the background section serves as a clear roadmap for a PHOSITA to integrate a proactive "push" notification mechanism into existing collaborative environments.

Obviousness Argument

A PHOSITA, at the time of the invention, would be familiar with the capabilities of existing groupware systems (Centripetal Method Groupware) and various "push" technologies, including email notifications with embedded hyperlinks and narrowcasting.

Combination: Centripetal Method Groupware (e.g., IBM Lotus Notes/Microsoft Exchange) + The "Explicitly Stated Improvement" (pushing notices with hyperlinks for appointments/reminders).

Rationale:

1. Centripetal Method Groupware provides core elements: These systems already provide:

   • Peripheral devices for participants to transmit and receive information.
   • A central agent (server) with two-way links to these devices.
   • A central storage medium capable of storing information inputs from participants.
   • The ability to store a first, second, and third information input from participants, and to associate them (e.g., for threaded discussions), as well as retaining, modifying, or deleting information.
   • Mechanisms for directing information to at least one receiving participant (e.g., through user permissions or group memberships).

2. The "Explicitly Stated Improvement" adds the "Centrifugal Push" mechanism: The '229 patent's background section explicitly teaches the desirability and mechanism of "pushing" information outward. It describes an "improvement" where "appointments and reminders for appointments" are "pushed" to group members "via e-mail with a Web hyperlink to the videoconference, via a narrowcast of the appointment". This "improvement" inherently encompasses:

   • A notice generator, responsive to an event (e.g., an appointment becoming due or a reminder trigger).
   • A notice sender (e.g., an email server or narrowcasting system).
   • The generation of a notice selectively for the at least one receiving participant (as appointments/reminders are typically for specific individuals).
   • The pushing of the notice to the notice sender.
   • The notice comprising a channel to a memory location (e.g., a "Web hyperlink to the videoconference").
   • The ability for the receiving participant to access the information directly using the channel.

A PHOSITA, motivated by the stated problem of users having to "remember to go" to a central area for collaboration and provided with the explicit suggestion to "push" notifications with hyperlinks for "appointments and reminders," would find it obvious to extend this "push with a channel" mechanism to any new participant-generated information input within a collaborative groupware system.

• For Independent Claim 1: Applying the "push with hyperlink" concept from the "improvement" to new "first information inputs" (e.g., a new document posted, a new discussion topic) from a participant in a Lotus Notes-like system would be a straightforward design choice. The hyperlink would simply point to the location of that new information in the central storage medium. Similarly, extending this to "second" and "third" information inputs (replies in a threaded discussion) would be an obvious way to maintain continuous awareness and address the "remember to report" problem for ongoing collaboration.
• For Independent Claim 22: The method steps of centrally receiving and storing information, associating it with participants, and then preparing and sending a notice with a channel selectively to those participants, mirrors the described "improvement" when applied to dynamic, participant-generated content within a collaborative system. The step of responding to subsequent inputs (second and third) with similar notices is an obvious extension for maintaining real-time or near real-time awareness in a dynamic collaborative environment.

Therefore, the combination of widely available groupware systems (e.g., IBM Lotus Notes or Microsoft Exchange) with the push notification technology (e.g., email with hyperlinks or narrowcasting) as explicitly suggested for improvement in the '229 patent's own background, would have rendered the claimed invention obvious to a PHOSITA at the time of the invention. The motivation is clearly to overcome the burden on users to manually retrieve information by proactively delivering relevant updates.