Invalidity dossier
US 7430715
Interface for indicating the presence of inherited values in a document
Current assignee: SAP SE
Added 9/24/2026, 5:11:13 AM
Active provider: DeepSeek · deepseek-v4-flash
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll verify the patent against external sources before summarizing.
Verification note
I searched Google Patents/Justia and broad web sources for the exact string 7430715. Results confirm a single US patent bearing that number — US 7,430,715 B2. I also ran a targeted search for CAFC 2026 docket activity involving this patent number and found no Federal Circuit or district-court litigation tied to 7430715; the hits that surfaced (an Exafer appellate amicus brief joined by Cisco/SAP, and a Supreme Court amicus brief by SAP America in No. 26-73) concern unrelated damages-law questions, not this patent. Treat that as a negative search result, not proof of absence — I cannot query PACER/CAFC dockets directly.
⚠️ Literal-ID caution: the search also returned JP 7430715 B2 (Japanese Patent No. 7430715), which is an unrelated YAP/TAZ-TEAD cancer-therapy patent. Do not conflate it with US 7,430,715. The number strings are similar but the documents are unrelated.
US 7,430,715 B2 — Summary
| Field | Value |
|---|---|
| Title | Interface for indicating the presence of inherited values in a document |
| Patent number | US 7,430,715 B2 |
| Application number | 11/141,984 |
| Filing date | 2005-05-31 |
| Priority date | 2005-05-31 |
| Issue (grant) date | 2008-09-30 |
| Pre-grant publication | US 2006/0271868 A1 (2006-11-30) |
| Original assignee | SAP (assignment recorded 2005-10-11; corrected 2007-05-15) |
| Current assignee | SAP SE (change of name from SAP AG, effective 2014-07-07) |
| Inventors | Dave L. Sullivan; David E. Brookler; Paul N. Weinberg; Richard T. Endo; Nathan F. Yospe; Philip A. Tinari |
| Classification | G06F 40/197 (version control); G06F 40/00, G06F 40/10 |
| Legal status (as listed) | Active; adjusted expiration 2026-11-08; 12th-year maintenance fee paid 2020-03-23 |
Abstract (verbatim)
"An interface for indicating the presence of inherited values in a document. The interface enables a user to rapidly determine if an audience specific document conforms to the expectations or requirements of an intended audience. The interface distinguishes between current, primary and secondary audience layer values through the use of color or any other mechanism that allows a user to quickly identify data that is missing and needs to be populated, changed or remain unchanged if the inherited data is suitable for the given audience. Using the interface, users can determine at a glance what information is inherited and what level of inheritance that information is from. Before generating an audience specific document targeted at a particular media type, an audience hierarchy may be created and utilized for entry and edit of data for a desired audience."
Plain-language overview of the independent claims
There are three independent claims (1, 12, 15) out of 17 total.
Claim 1 — Method for a color/visual-cued multi-audience data entry UI.
- Provide a UI with multiple fields showing "audience data" for a first audience.
- Get a current audience identifier from the user; that identifier defines a "current audience inheritance level."
- Pull a set of audience data chosen for its closest correspondence to that level (i.e., the best inherited value available).
- Display it with multiple visual representations, each showing the inheritance level for each field.
- Generate a first audience-specific document using that data.
- (Dependent claims add: data from multiple inheritance levels (2); import of external per-layer data (3); searching with an "audience layer operator" specifying which inheritance levels to search (4); editing an inherited value and re-coloring it as current-layer (5); editing so that two different audience documents both carry the edited value (6); media-type formatting (7–9); deriving the audience identifier from an environment variable (10) or a browser session variable (11).)
Claim 12 — Method for generating an audience-specific document from layered/inherited data.
- Get a first audience identifier (first audience layer) and retrieve that layer's audience data from a database.
- Present a UI where a first datum is annotated with a visual marker showing it belongs to the first audience layer.
- Also display a second datum annotated with a different visual marker showing it belongs to a second audience layer that is superior to the first in an audience hierarchy (i.e., the value is inherited from "above").
- Generate a document for the first audience from that data.
- (Claim 13 adds the edit-conversion behavior: editing the inherited datum changes its marker to the current layer and the edited value flows into the first audience's document while the superior audience's document retains the original value; claim 14 adds different media-type formatting. Claim 14 has a typographical defect in the granted text — it begins "he method of claim 12" rather than "The method of claim 12.")
Claim 15 — Computer-accessible memory medium (CRM) claim. Program instructions that:
- Display a UI containing: (a) a selection widget for picking an audience identifier; (b) a first data display able to show a representation of an audience hierarchy; (c) a second data display with multiple data fields for audience data.
- Obtain audience data from a data storage device.
- Populate the first display with the audience hierarchy (reflecting multiple inheritance levels).
- Populate the second display with a subset of the data, each datum selected by its inheritance level relative to the chosen audience identifier.
- Display indicia of inheritance level (relative to the audience identifier) for at least one datum.
- (Claim 16 adds generating the document in a plurality of media types; claim 17 adds an editing interface.)
Notable context
- Family: 11/141,984 sits alongside CIP children US 7,657,511 B2 (11/142,809, multi-layered data model for audience-specific documents) and US 7,640,255 B2 (11/204,763, method for utilizing a multi-layered data model), plus sibling filings US 7,912,861 B2 (testing layered data for a value) and US 7,647,302 B2 (searching layered data).
- Prior art of record includes Singh et al., "Generating Association Rules from Semi-Structured Documents Using an Extended Concept Hierarchy" (ACM 1997) and Spragins, "Developing Hypertext Documents for an International Audience" (ACM 1992) as non-patent citations, plus U.S. references such as Turner (language-specific data output) and O'Carroll (document processing/merging).
- Forward citations of note: IBM's US 7,996,773 and US 2009/0070680 ("Displaying and managing inherited values") and US 9,577,880/US 9,843,477 (scope of impact in inherited settings) — useful if the inheritance-UI concept area matters to you.
- Uncertainty: the $5,980,000 figure appearing on a third-party "patent leaderboard" page is an unverified valuation estimate from a non-authoritative source; I would not cite it as fact. Everything else above is grounded in the patent text itself and the Google Patents/Justia records returned in search.
Generated 10/1/2026, 11:24:12 AM
Cases on file (0)
Specific litigation cases in our database that name US patent 7430715. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll search litigation-specific sources for this patent number.
Initial searches returned only unrelated patents (including JP 7430715, which the earlier section flagged). Let me query litigation-specific sources directly.
Litigation search — US Patent No. 7,430,715
Bottom line
No litigation involving US 7,430,715 has been identified. After targeted searching of patent-litigation sources, I found zero district-court actions, zero Federal Circuit appeals, and zero PTAB proceedings (IPR/PGR/CBM) in which US 7,430,715 is a patent-in-suit or a challenged patent — as of the date of this report.
Because the required per-case fields (plaintiff, defendant, jurisdiction, case number, filing date, outcome) cannot be populated for a case that does not appear to exist, I am reporting the negative result rather than a case table.
Searches performed (all negative for '715)
| Query / source | Result |
|---|---|
7430715 patent litigation lawsuit |
No hit for US 7,430,715. Returned JP 7430715 B2 (Inventiva, YAP/TAZ-TEAD cancer therapy), a Lithuanian registry notice "Pranešimo Nr. 7430715," and an unrelated ANDA case referencing a different "'743 patent" (Axsome v. Alkem). |
"7,430,715" patent infringement lawsuit |
No hit. Returned Collision Communications v. Samsung (4 different patents), Bose v. Beats, TOT Power Control v. Apple, Sable Networks cases — none involving the '715 patent. |
"7,430,715" district court case number |
No hit. |
"7430715" IPR inter partes review PTAB |
No hit for the correct patent. Returned US 7,426,715 (Sound View Innovations) — a near-miss number, see below. |
unifiedpatents.com litigation "7,430,715" |
Unified Patents' portal/caselist content surfaced for many other patents; no 7,430,715 case list. |
SAP patent 7430715 lawsuit / SAP-as-party litigation |
Surfaces numerous SAP suits — Cyandia, Inc. v. SAP America, Inc. et al., 2:24-cv-00096-JRG (E.D. Tex., filed 2024-02-12); Valtrus Innovations Ltd. v. SAP America, Inc., 2:24-cv-00533-JRG (E.D. Tex.); Celonis SE v. SAP SE, 3:25-cv-02519 (N.D. Cal.); SAP SE v. TSX Inc.; SAP SE v. Trayport Ltd.; Teradata Corp. v. SAP SE, CAFC 22-1286 — but none of these plead US 7,430,715. |
⚠️ Two decoys you should not confuse with this patent
- JP Patent No. 7430715 B2 — Japanese patent (Inventiva Pharma), filed 2019-10-02 under PCT/EP2019/076681, granted 2024-02-02, titled "YAP/TAZ-TEAD interaction inhibitor and its use in treating cancer." The number string is identical; the document is entirely unrelated. (Source: patentimages PDF of JP7430715B2.)
- US Patent No. 7,426,715 (Sound View Innovations, LLC) — a different US patent, one digit transposed. This one was litigated and reexamined: Sound View asserted it against Walmart, Vudu, and Delta Air Lines, and Unified Patents obtained ex parte reexamination 90/014,558, with the Central Reexamination Unit granting the request on 2020-09-03 and issuing a final office action rejecting all challenged claims on 2021-10-04 (sources: unifiedpatents.com insights posts). Do not attribute any of that activity to 7,430,715.
Note on my earlier verification section: it already recorded a negative result for CAFC/docket activity on 7430715, and flagged the JP 7430715 conflation risk. This search is consistent with that and adds the US 7,426,715 decoy.
Why the absence is plausible (context, not proof)
- The patent is owned by SAP SE (assignment history: SAP AG → SAP SE, effective 2014-07-07). SAP is an operating software company, not an NPE, so a low assertion profile is expected.
- The last recorded legal event is the 12th-year maintenance fee paid 2020-03-23 (per the Google Patents legal-events record). A patent being actively asserted in litigation would typically show more recent post-grant activity; the record shows none.
- Its sibling/continuation-in-part family members (US 7,657,511 B2; US 7,640,255 B2) and sibling filings (US 7,912,861 B2; US 7,647,302 B2) likewise did not surface as asserted patents in these searches. These four appear only as patents citing/cited-by the '715 family, not as litigation vehicles.
Limitations — read before relying on this
- I could not directly query PACER, Docket Navigator, Lex Machina, or the Unified Patents litigation portal's case-list API; I relied on indexed public web results. A sealed, recently filed, or thinly indexed complaint could therefore be missed.
- District-court dockets are not fully crawled by public search engines, and complaints that plead "U.S. Patent No. 7,430,715" without the commas or with formatting variations ("7430715," "7,430,715," "US7430715") may not have been caught. My queries used both punctuated and unpunctuated forms.
- Negative results here mean "not found in the sources reached," not "provably nonexistent." Confirming a true negative requires a PAIR/PatentCenter "Litigation" tab check, a Docket Navigator patent-number search, and a PACER party-name sweep for SAP.
- One date inconsistency to flag: the instructions state the current date as April 26, 2026, while retrieved documents include material dated September 2026 (e.g., a 2026-09-28 article) and February 2026 court entries. The effective coverage of the search index therefore extends at least to late September 2026, later than the stated current date. I have not reconciled this; treat the search as current through at least that point.
Generated 10/1/2026, 11:24:29 AM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
Proceedings overview
Total AIA trial proceedings on US 7,430,715: zero. The canonical USPTO Open Data Portal (ODP) feed supplied in this analysis returns no IPR, PGR, or CBM proceedings for this patent, and independent web searches across PTAB decision indexes, PTAB E2E/TrialTracker-style aggregations, and news/legal-press commentary surfaced no AIA petition ever filed against 7,430,715 — no institution decisions, no Final Written Decisions, no settlements, no Director Review orders, and no Federal Circuit appeals from any PTAB proceeding.
Breakdown by status: active — 0; claims invalidated — 0; claims sustained — 0; settled — 0; institution denied — 0.
Bottom-line defensive posture: the patent is completely "un-hardened," but for a reason that is not favorable to a plaintiff — it has never been worth attacking. There is no PTAB record to mine for cancellation, no estoppel, and no adverse claim construction. But the far more important fact for a defendant today is the clock: per the structured record, the patent's adjusted expiration is 2026-11-08 — roughly five weeks from today's date of 2026-10-01. There is no AIA trial that could be filed and reach a Final Written Decision before the term runs out (35 U.S.C. § 316(a)(11) sets a 1-year trial deadline from institution, and institution itself takes ~6 months under § 314(b)). An IPR filed now would be mooted by expiration long before it could cancel anything.
Because no proceeding exists, the per-proceeding template that follows has no entries to populate. Rather than fabricate proceeding numbers (the instructions expressly forbid inventing them), I set out below what the absence of proceedings means and what is actually actionable.
There are no proceedings to report
The requested per-proceeding sections (### {PROCEEDING_NUMBER} — {Petitioner} v. {Patent Owner}) are intentionally omitted. Populating them would require inventing docket numbers, panels, and dispositions. I will not do that.
Two things are worth recording as affirmative negative findings:
- IPR unavailability is now a non-issue, but note why no IPR exists. For a pre-AIA patent filed 2005-05-31, IPR was available from 2012-09-16 onward with no filing window (post-SAS, and after the 2018 removal of the § 311(c)(1) one-year-from-grant bar for pre-AIA patents). So the absence of any IPR is not for lack of an available vehicle. It reflects that no one has ever been sued or credibly threatened on this patent — IPR filings are overwhelmingly litigation-driven.
- PGR and CBM were never options. PGR under § 321 applies only to first-inventor-to-file patents; 7,430,715 was filed 2005-05-31, so it is categorically ineligible. CBM review under AIA § 18 was available based on the patent's subject matter but the transitional program sunset on 2020-09-16 (AIA § 18(a)(3)(C)), and no CBM was filed during the eight-year window. Note the irony: the patent owner here is SAP, which was itself the first-ever CBM petitioner (SAP America, Inc. v. Versata Development Group, Inc., CBM2012-00001, the first CBM challenge filed on 2012-09-16) — yet SAP's own 7,430,715 was never the subject of a CBM or IPR by anyone.
Ex parte reexamination — checked, none found
No ex parte or inter partes reexamination of 7,430,715 appears in search results. ⚠️ Literal-ID caution — two look-alike numbers surfaced and must not be conflated:
| Number | What it actually is | Relation to this analysis |
|---|---|---|
| US 7,430,715 B2 | SAP, "Interface for indicating the presence of inherited values in a document" | This patent |
| US 7,426,715 | Sound View Innovations, LLC — "shutting down a plurality of software components in an ordered sequence"; subject of Unified Patents' ex parte reexam request (control no. 90/014,558), granted 2020-09-03 | Different patent. Do not attribute the Sound View reexam or its Walmart/Vudu/Delta litigation to 7,430,715 |
| JP 7430715 B2 | Inventiva (FR), YAP/TAZ-TEAD interaction inhibitor, JP App. 2021-518089 | Different patent. Already flagged in the prior section |
The Sound View hit in particular is easy to misread, because a Google Patents result can surface 7,426,715 alongside 7,430,715 on the same page. The '715 reexam is not about inherited values, audience layering, or documents at all.
Strategic summary
Claim status: all 17 claims are UNTESTED. No claim of 7,430,715 has been canceled, confirmed, or construed by the PTAB. Independent claims 1, 12, and 15 and their dependents (2–11, 13–14, 16–17) stand exactly as granted on 2008-09-30. There is therefore no narrowed claim set to point to and no invalidity ruling to leverage. Anyone asserting the patent today asserts the original claim scope.
Estoppel landscape: none, and that cuts both ways. Because no IPR resulted in a final written decision, no petitioner is estopped under 35 U.S.C. § 315(e)(2). There is no party barred from re-raising art it "raised or reasonably could have raised." Practically, this means all prior-art grounds remain available to a defendant — including the references already of record: Singh et al., "Generating Association Rules from Semi-Structured Documents Using an Extended Concept Hierarchy" (ACM 1997) and Spragins, "Developing Hypertext Documents for an International Audience" (ACM 1992), plus U.S. references such as Turner (US 2002/0069049, language-specific data output) and O'Carroll (US 6,772,165 / US 2003/0093755, document processing and node-by-node merging). But the same absence means there is no § 315(b) one-year bar problem, no Fintiv-style discretionary-denial fight, and no estoppel exposure to manage either. This is a greenfield.
The dispositive strategic fact is term, not validity. The adjusted expiration of 2026-11-08 means the patent is effectively at end of life during this analysis. Any defendant being asserted against should (a) confirm the expiration and any terminal disclaimer / PTA in the file wrapper, (b) check the 11.5-year maintenance fee (paid 2020-03-23, per the structured record) — with the 12th-year fee already recorded and only three maintenance windows in a utility term, no further fee is due, so no lapse risk, and (c) focus on damages-period exposure rather than invalidity. A § 286 damages look-back runs six years from complaint, so a complaint filed now reaches back to roughly 2020-10 — meaning the entire recoverable damages window sits in a term that has already substantially run.
Sibling-patent caveat. 7,430,715 sits in a family that also includes US 7,657,511 B2 (11/142,809, CIP — multi-layered data model for audience-specific documents), US 7,640,255 B2 (11/204,763, CIP — method for utilizing a multi-layered data model), US 7,912,861 B2 (11/142,806-line — testing layered data for a value), and US 7,647,302 B2 (searching layered data). I did not run a complete per-patent ODP query on each family member as part of this task, and the ODP block in this prompt covers 7,430,715 only. If you are facing a portfolio-wide assertion, run each family member's number through PTAB E2E separately — the family members issued 2010–2011 and have later expirations, so a challenge to one of them may still be a live option even though 7,430,715 itself is not worth attacking.
Recommended next steps
If you are a defendant and the demand cites US 7,430,715:
- Do not file an IPR. With ~38 days of term remaining as of 2026-10-01, you cannot get an institution decision (statutory ~6-month § 314(b) deadline), let alone an FWD within the 1-year § 316(a)(11) trial deadline, before expiration. Filing would be pure cost with no cancellation benefit. Confirm the expiration date yourself against the USPTO Patent Center file wrapper and the fee record rather than relying on the Google Patents "adjusted expiration" flag.
- Attack on the merits in court instead. With no estoppel and no PTAB narrowing, every § 102/§ 103 ground is on the table in district court — including the ACM 1992 and 1997 non-patent references of record and the Turner/O'Carroll references. Look hard at the claim 4 "audience layer operator" limitation and the claim 10/11 "environment variable / browser session variable" limitations, which are the most concrete and most prior-art-exposed elements.
- Run the damages math against the remaining term. Six-year look-back under § 286 from a complaint filed today reaches ~2020-10; the patent expires 2026-11-08. Any royalty base should be capped accordingly. Where the plaintiff delayed assertion of a 2008 patent it never litigated or licensed (apparently for 18 years), consider § 286 laches-adjacent arguments and SCA Hygiene–compatible equitable defenses — though note SCA Hygiene Prods. AG v. First Quality Baby Prods., 580 U.S. 328 (2017) holds laches is not a defense to damages.
- Verify the assignment chain via USPTO Assignment (the record shows the 2005-10-11 assignment from Sullivan/Brookler/Weinberg/Endo/Tinari, a corrected 2007-05-15 assignment naming Yospe, and the 2014-08-26 SAP AG → SAP SE name change). A standing challenge on an incomplete chain is cheap to raise and has no PTAB analogue.
Where to verify the negative finding yourself (I cannot query PTAB E2E directly from this environment):
- PTAB E2E / PTAB Center — https://ptacts.uspto.gov/ptabweb/ — search by patent number 7,430,715; the docket search will return zero proceedings if the ODP feed is correct.
- USPTO PTAB Decisions — https://developer.uspto.gov/ptab-api/ and the public decisions page — search by patent number for any FWD or institution decision.
- USPTO Open Data Portal (ODP) API — https://developer.uspto.gov/api-catalog — the stated canonical source for the "no proceedings" result in this prompt.
- CourtListener / RECAP — https://www.courtlistener.com/ — search
7,430,715and7430715for any district-court or Federal Circuit docket; my searches found none, and the earlier analysis in this matter likewise found no CAFC activity tied to this number. - Reexam control numbers — Patent Center, https://patentcenter.uspto.gov/ — confirm no 90/ or 95/ control number is associated. (Do not enter 90/014,558 — that is the Sound View 7,426,715 reexam, a different patent.)
Confidence and limits. I have high confidence that there is no AIA trial proceeding on 7,430,715: the ODP block says so and no search contradicted it. I have moderate confidence that the patent has never been asserted in district court — the searches were negative but I cannot query PACER, so treat that as a negative search result rather than proof of absence, exactly as the earlier section cautioned. I have not independently verified whether any family member (7,657,511, 7,640,255, 7,912,861, 7,647,302) has PTAB activity; that is outside the scope of this question and would require a separate per-patent ODP pull.
Generated 10/1/2026, 11:24:40 AM
Ownership chain (3)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2005-10-11 · reel 016873/0120 · Assignment
Brookler, David; Weinberg, Paul; Sullivan, Dave; Endo, Rich; Tinari, PhilipSAP, Aktiengesellschaft
? · recorded 2007-05-15 · reel 019303/0548 · Assignment
Sullivan, Dave L.; Brookler, David E.; Weinberg, Paul N.; and others (including Nathan F. Yospe)SAP, Aktiengesellschaft
? · recorded 2014-08-26 · reel 033625/0334 · Change of Name
change of name only
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll attempt to verify the assignment record against live sources before reconstructing the chain.
Let me try to resolve the correspondent of record, which the Google Patents legal-events block does not expose.
Inventors
All six named inventors are US-based individuals who assigned their rights to SAP at filing. The assignment instruments (executed Aug 2005 and Feb 2007) are the evidence for the employer call; I found no employment agreements, no SEC disclosures, and no corporate records tying any inventor to a different company.
| # | Inventor | Employer at filing (determinable basis) | Notes |
|---|---|---|---|
| 1 | Dave L. Sullivan | SAP AG — assignor on both recordings (exec. by 2005-08-29; again 2007-02-22/26) | First-listed assignor on the corrected record |
| 2 | David E. Brookler | SAP AG — assignor on both recordings | Also named on sibling filings US 2006/0271523 and US 2006/0288265 |
| 3 | Paul N. Weinberg | SAP AG — assignor on both recordings | Also named on US 2006/0268107 (testing layered data) |
| 4 | Richard T. Endo | SAP AG — assignor on 2005 record (transcribed as "ENDO, RICH") | |
| 5 | Philip A. Tinari | SAP AG — assignor on 2005 record | |
| 6 | Nathan F. Yospe | SAP AG — absent from the 2005-10-11 recording; added only by the 2007-05-15 recording | See pattern note below |
Employer caveat. The assignment of invention to SAP is strong but indirect evidence of employment — it proves conveyance of rights, not a payroll relationship. I could not determine whether the team joined SAP by hire or by acquisition of a predecessor. The '984 specification incorporates by reference a run of 2000–2004 applications (Ser. Nos. 09/577,268, 09/643,316, 09/643,207, 09/960,902, 10/022,056, 09/960,541, 10/172,572, 10/990,292–294) that appear to originate from the same technical team years before the 2005 filing. That is consistent with either a long SAP tenure or a team-and-portfolio acquisition, and I did not resolve which. Treat as unclear.
Unusual patterns.
- Missing-inventor correction, not a fire-sale precursor. Co-inventor Yospe was omitted from the original assignment (executed 2005-08-10 to 2005-08-29, recorded 2005-10-11) and was added only by the second instrument (executed 2007-02-22 to 2007-02-26, recorded 2007-05-15), i.e. ~21 months after filing. This is a chain-of-title completeness cure, the routine kind of defect that shows up in a Rule 3.73(b) statement later. It is not the "all inventors departing within 12 months" pattern.
- Both recordings are pre-issuance. The patent did not grant until 2008-09-30. There is no post-issuance assignment of the '984 patent at all — which is the single most important fact in this report.
- No evidence of inventor departure. I found nothing — no re-assignments away, no later filings by these inventors under a different corporate assignee for this subject matter. Not determinable, but the absence of any departing-inventor trail is itself a mild negative for the fire-sale thesis.
Original assignee
SAP Aktiengesellschaft (legal name as recorded 2005-10-11 and again 2007-05-15; also rendered "SAP, AKTIENGESELLACHAFT" in the 2005 record — a typographical variant in the USPTO transcription, not a separate entity). Walldorf, Germany. Renamed SAP SE effective 2014-07-07 (recorded 2014-08-26).
- Primary line of business: enterprise application software and enterprise data management. SAP is a publicly traded operating company (Frankfurt: SAP; NYSE: SAP).
- Current status: operating. Not acquired, not dissolved, not in bankruptcy. SAP's 2014 conversion from AG to SE was a legal-form change under EU law, not a sale.
- Did it ship a product embodying the claims? Plausible but not verified. The claimed subject matter — a data-entry/edit UI that shows current/primary/secondary audience inheritance levels in colours and generates audience-specific documents — maps onto SAP's master-data / product-information / catalog-publishing lines, and the specification incorporates by reference SAP-era applications titled "Accelerated System And Methods For Synchronizing, Managing, And Publishing Business Information" and "System And Method For Dynamically Constructing Synchronized Business Information User Interfaces." I could not confirm a named shipping product that practices claims 1/12/15 today, and I will not assert one. Mark as unverified product embodiment.
Material point for cross-reference against earlier sections: this patent sits with an operating company that (a) never transferred it, and (b) per the earlier litigation and PTAB sections of this analysis, has never been asserted in any district court, PTAB, or reexamination proceeding. Those two findings reinforce each other.
Assignment timeline
Three recorded assignment events exist. The underlying assignment abstracts were not retrievable from this environment, so I am relying on the legal-events transcription in the authoritative patent text. Two fields the Assignment Center normally exposes — the correspondent of record and the full recorded address block — are not present in that transcription. I flag each omission inline rather than fill it in.
2005-08-10 to 2005-08-29 (executed) / recorded 2005-10-11 — Reel 016873/0120
- Conveyance: Assignment
- Assignor: Brookler, David; Weinberg, Paul; Sullivan, Dave; Endo, Rich; Tinari, Philip — five of the six named inventors
- Assignee: SAP, Aktiengesellschaft (Walldorf, Germany)
- Correspondent: Not available. The transcription records only
ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS).Correspondent name, firm, and address as recorded cannot be determined from the sources I could reach. I will not guess one. - Context: Initial assignment of invention — inventors to employer, ~2.5 months after the 2005-05-31 filing and ~3 years before grant.
2007-02-22 to 2007-02-26 (executed) / recorded 2007-05-15 — Reel 019303/0548
- Conveyance: Assignment
- Assignor: Sullivan, Dave L.; Brookler, David E.; Weinberg, Paul N.; and others — the "and others" that distinguishes this record from the 2005 one is Nathan F. Yospe
- Assignee: SAP, Aktiengesellschaft (Walldorf, Germany)
- Correspondent: Not available (same limitation as above; the transcription records only
ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)). - Context: Correction/completion, not a transfer — the same assignee receives from the same assignors plus one omitted inventor. Beneficial ownership does not change.
2014-07-07 (effective) / recorded 2014-08-26 — Reel 033625/0334
- Conveyance: Change of Name
- Assignor: SAP AG
- Assignee: SAP SE
- Correspondent: Not available. The transcription records only
CHANGE OF NAME; ASSIGNOR: SAP AG; REEL/FRAME:033625/0334. - Context: Change of name only. Legal-form conversion AG → SE under German/EU law. No change in beneficial ownership, no consideration, no third party.
Also in the record but not assignments (listed here so the ownership chain is not confused with them): 2008-09-10 patent grant; maintenance-fee payments 2012-03-19 (4th year), 2016-02-25 (8th year), 2020-03-23 (12th year, large entity).
Reel/frame verification note. 016873/0120, 019303/0548, and 033625/0334 are taken from the legal-events block of the authoritative patent text. I could not re-confirm them against the Assignment Center's own display because I cannot query
assignmentcenter.uspto.govfrom this environment. They should be spot-checked before being cited in any filing or opinion.
Timeline diagram
timeline
title Ownership of US 7430715
2005 : App 11141984 filed by SAP AG
: Inventors assign rights to SAP AG
2007 : Corrective assignment adds N Yospe
2008 : Patent US 7430715 B2 granted
2014 : SAP AG renamed SAP SE
2026 : Adjusted expiry November 2026
NPE / troll-pattern signals
| # | Signal | Call |
|---|---|---|
| 1 | Shell-entity transfer | Not present |
| 2 | Known asserter in the chain | Not present |
| 3 | Repeat correspondent across the chain | Unclear — not assessable |
| 4 | Cascading transfers | Not present |
| 5 | Pre-litigation transfer | Not present |
| 6 | Bankruptcy fire-sale | Not present |
| 7 | Privateering | Not present |
| 8 | Defensive aggregator | Not present |
1. Shell-entity transfer — not present. The only assignee to appear in any recording, ever, is SAP, Aktiengesellschaft / SAP SE (Reels 016873/0120, 019303/0548, 033625/0334). No entity bearing "IP," "Patents," "Licensing," "Holdings," or "Ventures"; no LLC; no Delaware or Texas single-purpose vehicle; no registered-agent address appears anywhere in the chain. SAP is a publicly listed operating company, so the naming-plus-evidence pairing this test requires is absent.
2. Known asserter in the chain — not present. I compared the chain against the enumerated list (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities) and against Unified Patents / RPX high-frequency-plaintiff directories. Zero matches. The earlier litigation section independently found no suit, license demand, or RPX/Unified entry naming this patent.
3. Repeat correspondent across the chain — unclear, and I will not guess. This is the one signal whose primary evidence the Assignment Center holds and my sources do not. The correspondent of record for each of the three recordings is not exposed in the legal-events transcription, and my searches for the underlying assignment abstracts returned nothing usable. No finding either way. Two things are worth stating so this is not over-read later: (a) even if the same correspondent filed 016873/0120 and 019303/0548, that recurrence spans the same owner and the same law firm across two years and would be entirely ordinary, not a troll tell; (b) the meaningful version of this signal is one attorney's name recurring across different assignee LLCs, and there are no different assignees here.
4. Cascading transfers — not present. Three recordings across nine years. Only one of them (2005) moves beneficial ownership at all; the other two are a correction and a name change. There is no sub-24-month chain, no shared correspondent-address cluster, no common-principal pattern — because there is nothing to chain.
5. Pre-litigation transfer — not present. The last ownership-affecting recording is 2005-10-11. No suit naming this patent has been identified (see the earlier litigation and PTAB sections). There is no transfer within 6 months of any complaint, and no complaint to anchor the test to.
6. Bankruptcy fire-sale — not present. SAP AG filed no Chapter 7 or Chapter 11 proceeding. Its 2014 AG → SE conversion was a change of corporate form, not an insolvency event, and it required no transfer of the '984 patent to a buyer.
7. Privateering — not present. Privateering requires an operating company to transfer to an NPE that asserts on its behalf. No transfer to any third party occurred, and no assertion occurred. SAP retained the patent outright.
8. Defensive aggregator — not present. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at SAP SE. Note the direction of this: the patent has not been "neutralised" by an aggregator — it simply was never deployed.
Verdict
Insufficient data — in the literal menu sense of "only the original assignment."
Justification. Every ownership-affecting recording on US 7,430,715 is an inventor-to-employer assignment to SAP (Reel 016873/0120, recorded 2005-10-11; completed by the corrective assignment at Reel 019303/0548, recorded 2007-05-15), followed by a bare Change of Name to SAP SE (Reel 033625/0334, effective 2014-07-07). Not one of the eight NPE/troll signals is present, and the two that could conceivably be argued (correspondent recurrence, product embodiment) are marked unclear precisely because the underlying assignment abstracts and product evidence were not retrievable — not because they lean toward an NPE conclusion. This is the "original assignee still owns the patent" fact pattern the task brief anticipates, and the correct affirmative finding is the chain never left an operating company; there is no post-issuance transfer, no shell entity, and no asserter to report.
Verify directly at: USPTO Assignment Center — search patent number 7430715 (mirror index: https://assignment.uspto.gov/patent/index.html). Search the bare numeral 7430715 and application 11/141,984. Retrieve the three abstracts for 016873/0120, 019303/0548, and 033625/0334 and capture the correspondent of record field on each — that single field is the only material gap in this report.
Suggested follow-up if the correspondent field matters to you: pull the correspondents on the sibling family members — US 7,657,511 B2 (App. 11/142,809), US 7,640,255 B2 (App. 11/204,763), US 7,912,861 B2, US 7,647,302 B2 — plus the two 2006 sibling publications US 2006/0271523 and US 2006/0288265. If a single attorney/firm recurs across that cluster and those patents show up in an assertion campaign, that is the recurrence finding worth writing up. On this patent alone, there is nothing to write up.
Limits and confidence. High confidence on the inventor list, the assignee identity, the three recording dates, the conveyance types, and the AG → SE name change — all are stated in the authoritative patent text and corroborated by Google Patents/Justia. Moderate confidence on the reel/frame numbers, which I cite from the legal-events transcription and could not re-verify against the Assignment Center UI. No confidence asserted on correspondents of record or on any named shipping product — those fields are not populated and not invented. One residual check worth running: confirm via Patent Center that no unrecorded or late-recorded assignment exists, since an unrecorded instrument would be invisible to every source used here.
Generated 10/1/2026, 11:31:27 AM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll verify the patent and its citation record against live sources before analyzing the prior art.
Let me verify key references to characterize them accurately.
Verification first — this is US 7,430,715 B2, not a look-alike
| Check | Result |
|---|---|
| Patent number | US 7,430,715 B2 |
| Title | Interface for indicating the presence of inherited values in a document |
| Application | 11/141,984 · filed 2005-05-31 · granted 2008-09-30 |
| Pre-grant pub. | US 2006/0271868 A1 (2006-11-30) |
| Assignee | SAP SE (originally SAP AG) |
| Source used | Google Patents full-text record for US7430715B2 (confirmed live), which mirrors the USPTO file record |
⚠️ Literal-ID caution (unchanged from the earlier sections): the search returned JP 7430715 B2 (Inventiva, YAP/TAZ–TEAD cancer therapy) and, in an earlier analysis, US 7,426,715 (Sound View Innovations). Neither is this patent. Everything below is scoped strictly to US 7,430,715 B2. Nothing here disturbs the earlier findings of no litigation and no PTAB proceeding on this patent.
Statutory framing (important for the §102 analysis)
US 7,430,715 is pre-AIA (filed 2005-05-31), so §102 means pre-AIA §102. The §102(b) critical date is 2004-05-31 (one year before filing). References published before that date are §102(b); those published between 2004-05-31 and the 2005-05-31 filing are §102(a); U.S. applications/patents with an earlier effective filing date are §102(e). I flag §102(e) date problems where they arise (they matter a lot for the same-day SAP siblings).
The complete prior-art of record — 18 U.S. references + 2 non-patent references
The Google Patents record lists Patent Citations (18) and Non-Patent Citations (2). Below is each reference with citation, dates, a brief description, and my §102 mapping. "Potentially anticipates" is my analytic assessment of §102 exposure — I cannot see the examiner's actual rejection record, but the count of 18 references cited and the presence of close siblings strongly implies the examiner's operative rejections were §103 obviousness combinations, not clean single-reference §102 anticipation.
Tier 1 — Closest to the core concept (layered/inherited document data)
| # | Full citation | Priority / Pub. date | §102 basis | Brief description | Claim(s) it could potentially anticipate |
|---|---|---|---|---|---|
| 1 | US 6,772,165 B2 — O'Carroll, "Electronic document processing system and method for merging source documents on a node-by-node basis to generate a target document" (also pub. as US 2003/0093755 A1) | 2000-05-16 / 2004-08-03 (pub. 2003-05-15) | §102(e) (patent); §102(b) via its 2003 publication | Merges source document trees node-by-node; expressly supports document inheritance ("inherit content from an inherited source document") driven by flags and merge rules. | Closest reference for the inheritance data model underlying claim 12 ("second audience layer … superior … in an audience hierarchy"). But it merges documents, not audience data with per-field visual indicia — it does not reach claim 12's "annotated with … a plurality of visual representations," nor claim 1's per-field visual representations. Best characterized as §103 art against claims 12/13. |
| 2 | US 2006/0271523 A1 — Brookler et al., "Method for generating documents using layer-specific inheritance rules" | 2005-05-31 / 2006-11-30 | §102(e) questionable — same filing date as '715 | Same SAP family; document generation driven by layer-specific inheritance rules. | Directly on the "audience inheritance level" concept for claims 1, 12, 15 — but because it shares the '715 filing date, it cannot qualify as §102(e) art on its face (no "filed before" the applicant's invention). Treat as co-pending/double-patenting or §103 material, not clean §102 anticipation. |
| 3 | US 2006/0288265 A1 — Brookler et al., "Multi-layered data model for determining image choice across a set of audience-specific documents" | 2005-05-31 / 2006-12-21 | §102(e) questionable — same day | Multi-layered (audience) data model selecting images per audience. | Relevant to claim 12 and to the picture-border inheritance aspect (claim 5's visual-representation concept, Fig. 2's Picture values 204); same date problem as #2. |
| 4 | US 2006/0268107 A1 — Weinberg et al., "Method for testing layered data for the existence of at least one value" | 2005-05-31 / 2006-11-30 | §102(e) questionable — same day | Tests layered (audience) data for the existence of a value — i.e., the inheritance look-up / NULL testing logic. | Relevant to the data-selection step of claims 1 and 12 ("selecting a set of audience data … closest correspondence") and to claim 4's search operators; same date problem. |
Note on the four same-day siblings (#2–#4 above, plus the '715 itself): these are the SAP "layered data" family filings all bearing the 2005-05-31 priority date. Because §102(e) requires the reference to be filed before the applicant's invention, same-day co-pending applications generally do not qualify as §102(e) art absent proof of an earlier actual reduction to practice. Any §102(e) treatment of these four is therefore contestable — a point worth raising if one is ever asserted.
Tier 2 — Language/audience-output generation (the "audience identifier" and multi-language aspects)
| # | Full citation | Priority / Pub. date | §102 basis | Brief description | Claim(s) it could potentially anticipate |
|---|---|---|---|---|---|
| 5 | US 2002/0069049 A1 — Turner, "Dynamic determination of language-specific data output" | 2000-12-06 / 2002-06-06 | §102(b) | Determines a preferred language based on a user identifier and generates language-specific output from a descriptor database into output "zones." | Strongest §102 candidate for the front half of claim 1 ("obtaining a current audience identifier … selecting a set of audience data … to populate said plurality of fields") and for claim 11 ("information from a browser session variable") / claim 10 (environment variable as the identifier source). It does not disclose inheritance layers or per-field inheritance indicia, so claims 1/12/15 are not fully anticipated. |
| 6 | US 2002/0162093 A1 — Zhou, "Internationalization compiler and process for localizing server applications" | 2001-04-30 / 2002-10-31 | §102(b) | Compiler/process for localizing server applications to locales. | Background for the multi-audience/localization setting of claim 1; §103 fodder. |
| 7 | US 2003/0012558 A1 — Kim, "Information storage medium containing multi-language markup document information, apparatus for and method of reproducing the same" | 2001-06-11 / 2003-01-16 | §102(b) | Multi-language markup documents. | Possibly relevant to claim 8 ("media type is viewable in a browser") in combination; weak §102 alone. |
| 8 | US 2006/0217960 A1 — Fuji Xerox, "Translation device, translation method, and storage medium" | 2005-03-25 / 2006-09-28 | §102(e) (filed 2005-03-25 < 2005-05-31) | Translation device/method for producing translated content. | §103 material for the audience/language difference handling in claim 1; not anticipation. |
| 9 | US 6,542,898 B1 — Motive Communications, "Technical support chain automation with guided self-help capability using active content developed for specific audiences" | 1999-05-12 / 2003-04-01 | §102(b) | Guided self-help content developed for specific audiences. | Cited for the term "audience"; relates only loosely to claim 1's "audience data." Not anticipation of the inheritance-UI concept. |
Tier 3 — Document generation / data-attribute search (background)
| # | Full citation | Priority / Pub. date | §102 basis | Brief description | Claim(s) generally relevant to |
|---|---|---|---|---|---|
| 10 | US 2005/0086579 A1 — Leitner, "Systems and processes for automated criteria and attribute generation, searching, auditing and reporting of data" | 2003-06-13 / 2005-04-21 | §102(a) | Automated criteria/attribute generation and searching/reporting. | Background for claim 4 ("searching … utilizing an audience layer operator") — attribute/criteria searching. §103 material. |
| 11 | US 2007/0157079 A1 — Baker, "Apparatus and method for negotiating and generating contract documents on-line" | 2001-08-31 / 2007-07-05 | §102(e) | On-line document generation negotiation. | Background for claim 1's "generating … document" step. Weak. |
| 12 | US 2007/0067297 A1 — Kublickis, "System and methods for a micropayment-enabled marketplace with permission-based, self-service, precision-targeted delivery of advertising … to anonymous internet users" | 2004-04-30 / 2007-03-22 | §102(e) | Targeted content delivery to user segments. | Appears cited for "audience/segment targeting" broadly; only distant relevance to claim 1. |
| 13 | US 2002/0002567 A1 — Kanie, "Method and system for managing documents" | 2000-06-30 / 2002-01-03 | §102(b) | Document management. | Background; no inheritance/audience-UI teaching. |
| 14 | US 2002/0049831 A1 — Lifefiles.Com, "System for generating a web document" | 2000-09-01 / 2002-04-25 | §102(b) | Generating a web document. | Background for claim 8 (browser media); weak. |
| 15 | US 6,711,740 B1 — Cisco, "Generic code book compression for XML based application programming interfaces" | 2002-01-17 / 2004-03-23 | §102(b) | XML-API codebook compression. | Appears tangential — likely cited as general XML/API art; no evident claim nexus. |
| 16 | US 2006/0041428 A1 — Fritsch, "Automated extraction of semantic content and generation of a structured document from speech" | 2004-08-20 / 2006-02-23 | §102(e) | Produces a structured document from speech. | Cited for "generation of a structured document" generally; no inheritance/audience-UI teaching. |
Tier 4 — Reference cited that is not §102 art on its face
| # | Full citation | Priority / Pub. date | §102 basis | Note |
|---|---|---|---|---|
| 17 | US 2007/0067728 A1 — Lo, "Method for enforcing group oriented workflow requirements for multi-layered documents" | 2005-08-31 / 2007-03-22 | Not §102(a)/(b)/(e) — filed 2005-08-31, after the '715 filing (2005-05-31) | Multi-layered documents/workflow, but its effective date post-dates '715, so it cannot be §102 art. It is consistent with the specification's trailing incorporation list ("…are all hereby incorporated herein by reference. PLUS THE LATEST ONES") — an unfilled placeholder in the granted text. |
Non-patent literature (2 references — both §102(b))
| # | Full citation | Date | §102 basis | Description | Claim(s) it could potentially anticipate |
|---|---|---|---|---|---|
| NPL-1 | Spragins, "Developing Hypertext Documents for an International Audience," ACM, 1992, pp. 27–34 | 1992 | §102(b) | Designing hypertext/markup documents for an international audience. | Closest NPL to the preamble of claim 1 ("audience data") and claim 8 (browser-viewable media). Does not disclose inheritance layers or per-field visual inheritance indicia. |
| NPL-2 | Singh et al., "Generating Association Rules from Semi-Structured Documents Using an Extended Concept Hierarchy," ACM, 1997, pp. 193–200 | 1997 | §102(b) | Derives association rules from semi-structured documents via a concept hierarchy. | Relevant to the "audience hierarchy" limitation of claim 12 (and the hierarchy-recursion of claim 1). Not a disclosure of audience-layered inheritance or its visual indication. |
Bottom line on §102
No single reference of record appears to anticipate any independent claim (1, 12, or 15) in full. Every independent claim requires the combination of (a) an audience-layer inheritance data model, (b) selection of data by closest correspondence to the current audience level, and (c) multiple per-field visual representations indicating the inheritance level, followed by (d) audience-specific document generation. The references collectively teach pieces — O'Carroll teaches document inheritance; Turner teaches language-from-user-identifier output; the SAP siblings teach layered inheritance rules; Spragins/Singh teach international-audience hypertext and concept hierarchies — but none discloses the visual inheritance-level indicia that is the point of the invention.
The most §102-relevant references are: Turner (US 2002/0069049 A1) for the audience-identifier/selection aspects (claims 1, 10, 11); O'Carroll (US 6,772,165 B2 / US 2003/0093755 A1) for the hierarchy/inheritance aspects (claim 12); and the SAP sibling applications (US 2006/0271523 A1, US 2006/0288265 A1, US 2006/0268107 A1) for the layer-specific inheritance concept (claims 1, 12, 15). The two NPL references (Spragins 1992, Singh 1997) are strong §102(b) background for the "audience"/"hierarchy" language.
§102(e) date defect worth flagging: the three sibling applications (and the '715 itself) all carry the 2005-05-31 priority date. Same-day co-pending applications generally fail §102(e)'s "filed before the invention" requirement. If any of these siblings was used as §102(e) art, that basis is vulnerable.
Characterization of the examiner's art: given 18 citations and this constellation of partial teachings, the operative rejections were almost certainly §103 (and possibly §102(e) against the O'Carroll/Turner references), not clean §102 anticipation of the independent claims. The dependent claims most exposed to single-reference attack are the mechanical ones — claim 8 (browser media, cf. Spragins/Kim), claim 9 (paper media), and claim 10/11 (environment/session-variable audience identifier, cf. Turner).
Caveats
- I read this from the authoritative Google Patents full text (which reproduces the USPTO record) plus confirming searches; I cannot query the USPTO PatentCenter API directly from this environment, and I do not have the examiner's actual Notice of Allowance/rejection record. The "potentially anticipates" mappings above are my §102 assessment, not a quotation of the examiner's grounds.
- Dates are given as the record's priority date and publication date; where those differ from the actual filing date I have said so. For the three same-day SAP siblings, the priority date equals the filing date.
- The "$5,980,000" figure on the third-party Patent Leaderboard page (which surfaced again in search) remains an unverified, non-authoritative valuation estimate — not cited as fact.
- For ground-truth verification of any single reference, use https://patents.google.com/patent/US7430715B2/en (full file record) and https://patentcenter.uspto.gov/ for the application's citation/IDS history.
Generated 10/1/2026, 11:31:44 AM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the obviousness analysis in the prior art of record for this patent. Let me verify what the key references actually disclose before mapping them to the claims.
Let me verify the remaining "of record" references before building the grounds of rejection.
Obviousness Analysis — US 7,430,715 B2 under 35 U.S.C. § 103
Builds on the prior Patent Summary, Litigation, and PTAB sections. Not repeating their content except where a contradiction must be flagged.
0. Two cross-reference flags before the analysis
- Date inconsistency (carried forward). This task states the current date as April 26, 2026. The previously generated PTAB section used 2026-10-01 and described "roughly five weeks" of term remaining. The two cannot both be the "current date." Obviousness analysis does not turn on it, but the expiration math does — treat the earlier "~38 days remaining" framing as keyed to 2026-10-01, and this analysis as keyed to your stated 2026-04-26.
- Claim-text literalness. The prior summary rendered claim 1's operative phrase as "closest correspondence." The granted text actually reads "conespondence" (a typographical defect, like claim 14's "he method"). Per the strict-literal-ID rule, I analyze the claim as written but use "correspondence" as the plain meaning a court would apply (no claim term is saved or lost by the typo).
1. Governing framework
Which § 103 applies. 11/141,984 was filed 2005-05-31 — before the AIA first-inventor-to-file cutoff of 2013-03-16. This is a pre-AIA patent. Section 103(a) as it stood pre-AIA governs, and the pre-AIA § 102 categories (including § 102(e) "published application filed before the applicant's invention") define what counts as prior art.
The test. Graham v. John Deere Co., 383 U.S. 1 (1966): (1) scope/content of the prior art; (2) differences between prior art and claims; (3) level of ordinary skill; (4) secondary considerations. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) governs the combination question. MPEP 2141–2145 supplies the examining framework: for each claim, identify the differences, articulate a reason the differences would have been obvious (MPEP 2143), and confirm a reasonable expectation of success.
The controlling reality from the prior sections. No PTAB, no litigation, no § 315(e) estoppel, no narrowing amendment. So an obviousness attack asserts the original 2008 scope of claims 1, 12, and 15 and dependents. That cuts for a challenger: no prosecution-history narrowing to work around, and the full field of art is available.
Section 103(c) — the issue the "prior art" table hides. The of-record "cited" references include four SAP-family publications: US 2006/0217960 A1 (Weinberg), US 2006/0271523 A1 (Brookler), US 2006/0288265 A1 (Brookler), and US 2007/0067728 A1 (Lo). These are commonly owned by SAP and share inventors (Brookler, Weinberg are named inventors on the '715 patent itself). Under pre-AIA 35 U.S.C. § 103(c) as amended by the CREATE Act (applicable to applications filed on/after 2004-12-10 — this one qualifies), commonly-owned § 102(e)/(f)/(g) subject matter is affirmatively disqualified as § 103 art. They also fail the "by another" requirement for overlapping-inventor subject matter. They must not be used in any combination below. Any invalidity contention that leans on them is defeating itself. This is a genuine strength for the patent owner and must be respected.
That leaves the real prior-art arsenal of record:
| Ref | Identity | Where it bites |
|---|---|---|
| Turner | US 2002/0069049 A1, "Dynamic determination of language-specific data output" | Audience-ID-driven selection + fallback language hierarchy |
| O'Carroll | US 6,772,165 B2 / US 2003/0093755 A1, node-by-node document merge with inheritance | The entire inheritance architecture, incl. multi-language inheritance and session-variable selection |
| Spragins | ACM SIGDOC 1992, "Developing hypertext documents for an international audience" | "multiple layers of text that correspond to each level" of audience; visual cues |
| Singh et al. | ACM CIKM 1997, "…Extended Concept Hierarchy" | Data values mapped to nodes of a parent/child hierarchy; redundancy avoidance via lookup |
| Motive '898 | US 6,542,898 B1 | Audience hierarchy; audience-tailored content delivery to "specific audiences" |
| Ming Zhou | US 2002/0162093 A1 | Localization/resource separation for multi-locale applications |
| Kanie '567 / Lifefiles '831 / Kim '558 / Leitner '579 | various | Document management, web-doc generation, multi-language markup, attribute search/audit |
2. Level of ordinary skill (POSITA)
A POSITA as of May 2005 would be a software engineer with a bachelor's in CS/EE (or equivalent) and 2–3 years building document-generation, content-management, or localization/localization-tooling applications, with working familiarity with markup languages (HTML/XML), relational databases and lookup tables, and GUI data-entry/editor design. This is a low-to-moderate skill level, which favors the patentee only weakly — the art is implementational, and the references below are all squarely in it.
Pertinent art: all of Turner, O'Carroll, Spragins, Singh, and Motive '898 are within the field of multi-audience/multilingual document generation and data organization. There is no non-analogous-art argument available to the patentee.
3. Claim construction of the load-bearing terms
| Term (claims) | Construction | Why it matters |
|---|---|---|
| "audience inheritance level" / "audience layer" (1, 12, 15) | A provenance rank in a hierarchy of audiences: a value either lives at the current level or is inherited from a higher/other level | The novelty rides entirely on displaying provenance, not on inheritance itself |
| "selected for its closest conespondence" (1) | Fallback selection: pick the best-available value for the current audience, walking the hierarchy if absent | Turner's replacement-language table reads on this |
| "second audience layer is superior … in an audience hierarchy" (12) | The layer from which the current layer inherits | O'Carroll's inherited (fixed-role) vs. inheriting (movable-role) document |
| "plurality of visual representations, each indicative of … inheritance level for each … field" (1); "indicia of audience inheritance level" (15) | A per-field visual marker (color, typeface, border, icon) that tells the user where each field's value came from | This is the patent's only real candidate for non-obviousness — see § 8 |
4. Grounds of rejection
GROUND 1 — Claims 1–11 over Turner in view of O'Carroll and Spragins
(+ Singh or Motive '898 for the optional/claimed search and hierarchy features)
Why this is the lead ground: Turner supplies the audience-ID + fallback-selection + UI-rendering core; O'Carroll supplies the inheritance architecture and hierarchy (including express multi-language inheritance); Spragins supplies the "layers per audience level" concept and the visual-cue motivation. All three are in the same field and address the same problem.
| Claim 1 element | Reference / disclosure |
|---|---|
| UI with plurality of fields displaying audience data for a first audience | Turner FIGS. 3–4: a form/UI rendered in English (FIG. 3) and German (FIG. 4), field-by-field (Name, City, State, Zip…). Same UI, different audience |
| Obtain current audience identifier from user; identifier indicative of current audience inheritance level | Turner FIG. 5: User Identifier → Preferred Language Identifier table; the preferred-language value is the "current audience identifier." O'Carroll [0157]: inherit list determined from "a configuration file, a database, or a session object" — the audience layer is a runtime-selected parameter |
| Select a set of audience data for closest correspondence to the current level | Turner FIG. 6: Preferred Language → **Replacement Language** (German→English, French→Spanish, Spanish→English, Italian→French, Russian→German). That substitution table is a fallback hierarchy — if the preferred audience's data is absent, the next-best is returned |
| Display the data with a plurality of visual representations, each indicative of the inheritance level per field | Spragins (hypertext "multiple layers of text" per audience level; "clear visual representation"; window titles as "visual cues") + O'Carroll [0108]/[0123–0124] (composite nodes that favour the inherited vs. the inheriting document — the underlying provenance distinction the indicator would represent). The specific color/typeface mapping is a design choice (§ 5) |
| Generate a first audience-specific document from the selected data | Turner (language-specific output generation) + O'Carroll [0071–0072] (parse → merge → render target document for the requested language) |
Dependents under Ground 1:
- 2 (data from multiple inheritance levels): O'Carroll multiple inheritance — claim 18/[0135], "successively merging pairs of documents … until all source documents have been merged"; Turner's fallback chain.
- 3 (import external per-layer data): O'Carroll [0146] — inherited files "identified by … any other naming convention, for example Internet URLs," retrieved "via HTTP" from another computer; Turner's tables are externally populateable. Importing external data per layer is the ordinary way to build such a store.
- 4 (audience-layer operator for search) — weakest link. Searching with a "layer" operator is not squarely taught by the core set; Singh (values mapped to hierarchy nodes, with lookups against those nodes) or Leitner '579 (attribute search/audit/reporting) supplies searching over attributes. Expect the patentee to fight hardest here. See § 8.
- 5 (edit an inherited value → it becomes a current-layer value with a new visual representation): O'Carroll inheritance policies
prefer_inheriting/prefer_inherited/merge[0123–0124] andinherit_tag/overwrite_attributes[0108] — when the inheriting document supplies its own value it stops being inherited. The patentee's own spec concedes this is the natural consequence of setting a value locally ("the data value entered no longer inherits from another layer"). - 6 (edit so two different audience documents both carry the edited value): the mirror case — editing the inherited/superior document propagates to all inheriting documents (O'Carroll's whole point: "Updating information for multiple audiences occurs automatically" is even stated in the '715 background as a benefit of hierarchies).
- 7–9 (media-type formatting; browser; paper): O'Carroll [0074] renders to a browser (FIG. 5 is a browser screen shot) and supports multiple target syntaxes/languages; paper output is a design choice for a document generator.
- 10 (audience identifier from an environment variable): O'Carroll [0157] "a configuration file" / external source.
- 11 (audience identifier from a browser session variable): O'Carroll [0157] "a session object, i.e. an object containing information about the user and his/her activity." This is the strongest single-reference hit in the entire record. Claim 11 is the most vulnerable dependent claim.
GROUND 2 — Claims 12–14 over O'Carroll in view of Turner (and Spragins)
O'Carroll alone discloses most of claim 12; Turner supplies the audience-identifier retrieval and database layer; Spragins supplies the visual annotation incentive.
| Claim 12 element | Reference / disclosure |
|---|---|
| Obtain first audience identifier associated with audience data for a first audience layer | Turner FIG. 5 preferred-language table; O'Carroll [0157] runtime determination of the inherit list |
| Obtain the audience data for the first layer from a database | O'Carroll [0172] — the hierarchical representation "may be stored … in relational, object oriented, or hierarchical database management systems"; [0104] "treating the result of a database query as a movable role tree" |
| Present a UI where a first datum is annotated with a visual representation indicating correspondence to the first audience layer | O'Carroll [0108]/[0114–0115] composite nodes from the fixed (inherited) tree vs. values contributed by the movable (inheriting) tree; Spragins visual-cue teaching |
| Display a second datum annotated differently, indicating correspondence to a second audience layer that is superior in a hierarchy | O'Carroll [0074]: "the inherited tree has the fixed role and the inheriting tree has the movable role" — the inherited document is the superior layer; [0103]: "a HTML page which supports multiple languages … could inherit from a different parent depending on the language requested" |
| Generate a first audience-specific document from the first layer's data | O'Carroll [0071–0072], [0127–0129] (recursive bottom-up merge → final target document) |
Dependents under Ground 2:
- 13 (edit the inherited datum → its marker changes to the current layer; the current audience's doc gets the edit while the superior audience's doc keeps the original): O'Carroll's non-symmetry ([0102]: "a document A merged with a document B produces a different result from document B merged with document A") and the
prefer_inheriting/mergepolicies ([0124]) produce exactly this: editing locally yields a value that is no longer inherited and that does not propagate upward. Claim 13 is largely a tautology of any working inheritance model. - 14 (different media-type formatting for the second document): O'Carroll's multi-target-syntax rendering ([0101] "source documents and the target document may each observe different syntax rules"; [0074] browser rendering) + design choice for paper. Expect real § 103 resistance here only if the patentee can show a non-obvious cross-media formatting effect — which the spec does not claim.
GROUND 3 — Claims 15–17 over Lifefiles '831 / Kanie '567 in view of Turner, O'Carroll, and Singh
Claim 15 is a CRM claim whose subject matter is, functionally, "a tree view + a detail grid + provenance indicators."
| Claim 15 element | Reference / disclosure |
|---|---|
| Selection widget for choosing an audience identifier | Turner FIG. 5/6 (language selection); Kanie '567 (document management UI) |
| First data display capable of showing a representation of an audience hierarchy | Singh ECH: "a tree structure … parent, child, and sibling relationships" with "data values to every node" — i.e., a displayable hierarchy of data values; O'Carroll inherit-list structure |
| Second data display with a plurality of data fields for audience data | Turner FIGS. 3–4 form fields; Kanie/Lifefiles data-entry UI |
| Obtain audience data from a data storage device | O'Carroll [0172] (database/memory/disk); Singh's lookup-table implementation |
| Populate first display with the hierarchy reflecting multiple inheritance levels | Singh (values at every level) + O'Carroll (multi-level, multiple-inheritance) |
| Populate second display with a subset selected by inheritance level relative to the identifier | Turner fallback selection (FIGS. 5–6) |
| Display indicia of inheritance level for at least one datum | Spragins (layers/visual cues) + design choice |
Dependents: 16 (generate in a plurality of media types) — O'Carroll multi-syntax/rendering + Kanie/Lifefiles web-doc generation; 17 (editing interface) — O'Carroll [0075] expressly describes an "editing tool" that "processes pages in run time, and displays the target document for approval by the designer," plus the inherent editability of the form fields in Turner.
5. Why a POSITA would have been motivated to combine (the KSR rationales)
A combination must come with a reason, and the record supplies several independent ones. Any one suffices; together they are strong.
Same field, same problem, predictable result (MPEP 2143.01(IV)). Turner, O'Carroll, and Spragins each target producing documents for multiple language/regional audiences — the exact problem stated in the '715 specification's own Background. Combining a multilingual output engine (Turner) with a document-inheritance engine (O'Carroll) yields nothing more than the predictable aggregate of their known functions. KSR holds this is obvious.
The patent's own Background concedes the field. The '715 Background states that "current systems provide mechanisms for publishing documents in multiple languages" and that the remaining problem is (i) redundant data entry and (ii) the absence of visual clues because "there is no concept of inheritance in current systems." That is a problem-recognition admission: the entire asserted inventive contribution reduces to adding a visual indicator to a known inheritance model. Under KSR, "the desire to enhance" a known technique is itself a recognized reason to combine.
A known technique improving a similar device in the same way (MPEP 2143.01(VI)). Singh's ECH already solves the redundancy half of the problem ("To avoid this redundancy, this information can be placed in a lookup table") by mapping values to hierarchy nodes. Applying a hierarchy-node indicator to a data field is the same technique applied to the same data-organization problem.
Express teaching of the multi-language inheritance use case in O'Carroll. O'Carroll [0103]: "a HTML page which supports multiple languages. Such a page could inherit from a different parent depending on the language requested. Each language supported can be defined in a separate inherited document and merged … in the user's choice of language." This is not an after-the-fact motivation — it is the reference explicitly pointing at the '715 use case.
"Obvious to try" with a finite, predictable set (MPEP 2143.01(V)). Given a per-field inheritance architecture, the ways to show a user which fields are inherited are few and all conventional (color, bold/italic, border, icon). By 2005, distinguishing "overridden/local" from "inherited/default" values with a color or typeface was a ubiquitous convention in software UIs. Selecting among a handful of known display conventions is not invention.
No teaching away. None of the of-record references disparages displaying provenance. Spragins affirmatively encourages visual cues ("the technical communicator must convey this organizational structure to the reader by means of a clear visual representation").
The "obvious design choice" doctrine (MPEP 2144.04; In re Paulsen). Where the only difference is a visual indicator on a known data structure, the Board and Federal Circuit routinely affirm obviousness — a status indicator is a design choice, and the '715 spec's own "black/green/red … or bold/regular/italic … or any other mechanism" language concedes that the particular indicator is arbitrary.
6. Reasonable expectation of success
High. Every element is mechanical implementation of known techniques: a fallback table (Turner), a merge/inheritance engine over a tree (O'Carroll), a hierarchy with values at nodes and lookup tables (Singh), and a per-field text attribute that changes the render color/typeface (routine GUI). No element requires new science, and the combination produces no unpredictable interaction. A POSITA would have expected the combination to work "as it says on the tin." This satisfies the third KSR prong and the MPEP 2143.02 requirement.
7. Mapping the independent claims to the best single references (for § 102/§ 103 framing)
- O'Carroll alone is perilously close to claim 12 — it discloses audience-layer data, a UI-composite distinction between inherited and inheriting (superior/subordinate) values, database storage, and generation of the audience-specific document. Claim 12's survival hinges almost entirely on reading "annotated with a visual representation" into the merge machinery. If a court or the Board construes that limitation as requiring a user-visible marker, O'Carroll is not a § 102 hit but is a devastating § 103 primary reference; if construed more broadly (any data tag distinguishing provenance), O'Carroll threatens § 102 anticipation of claim 12.
- Claim 11 (session variable) is essentially anticipated by O'Carroll [0157]'s "session object" passage when read with a browser-based implementation ([0074]–[0075], [0167] client-side caching in a browser).
- Claim 10 (environment variable) is met by O'Carroll's "configuration file … or other information available … from an external source."
8. Where the patent may still survive — the honest counter-case
I would be doing you a disservice to present this as a slam-dunk. The genuine defensive kernel is narrow but real:
No of-record reference squarely teaches per-field, user-visible, inheritance-level-differentiated marking inside a data-entry/edit grid. Spragins teaches layers of text and visual cues about structure — but as a hypertext-navigation concept, not as a field-level provenance badge in a data editor. O'Carroll distinguishes inherited vs. inheriting content, but its figure shows a rendered page (FIG. 5), not an editor annotating each field's provenance. The patentee will argue the examiner considered exactly this art (Spragins and Singh are of record and the case still issued) and that the claimed combination of (hierarchy + per-field provenance indicator + edit-to-promote) was not taught. That argument has force because claims 5/13 (edit converts an inherited value to a current-layer value and changes its indicator) are the most concretely "UI-behavioral" limitations, and the references teach the data consequence, not the indicator update.
Claim 4's "audience layer operator." Nothing of record teaches a search operator that selects which inheritance layers to search. This is the single most defensible limitation in the patent, and it should be your hardest target if you are the patentee and your easiest concession if you are the challenger drafting a claim chart (i.e., you will need an out-of-record reference — a database query-language/bitmask teaching — or a "routine programming" argument under MPEP 2144.04/2146).
The § 103(c) exclusions are a real shield. As shown in § 1, four of the "cited" references cannot be used in any combination. If a challenger's invalidity contentions were built on the SAP-family publications, they are legally unavailable and the contentions fail. Confirm any contention you receive does not rely on them.
Secondary considerations: no evidence on record either way. The prior sections found no licensing, no litigation, no PTAB, no known commercial-success narrative tied to this patent. So there is no objective indicia to rebut a prima facie case — but also nothing to rebut, because the prima facie case above is a paper case that has never been tested. The realistic posture is: a well-constructed combination (Turner + O'Carroll + Spragins, with Singh for the hierarchy) would likely render claims 1–3 and 5–17 obvious, while claims 4 and (arguably) 13 are the ones to watch.
9. Bottom line
- Applicable law: pre-AIA § 103(a); Graham/KSR; MPEP 2141–2145. Low-to-moderate POSITA; all references analogous art.
- Available art of record for § 103: Turner, O'Carroll, Spragins, Singh, Motive '898, Ming Zhou, Kanie, Lifefiles, Kim, Leitner, Fritsch, and the O'Carroll sibling publication — with the four SAP-family publications and Lo necessarily excluded under § 103(c) (common ownership, overlapping inventors).
- Best combinations:
- Claims 1–11: Turner + O'Carroll + Spragins (+ Singh/Leitner for claim 4). Claim 11 in particular is near-anticipated by O'Carroll's "session object" passage; claim 10 by its "configuration file."
- Claims 12–14: O'Carroll + Turner + Spragins. O'Carroll's [0103] multi-language inheritance passage is the killer disclosure and the strongest single motivation to combine.
- Claims 15–17: Lifefiles/Kanie + Turner + O'Carroll + Singh (tree-view + detail-grid + provenance indicator).
- Motivations to combine: same field/same problem; the patent's own Background concedes the problem; O'Carroll expressly points at multi-language inheritance; Spragins affirmatively calls for a "clear visual representation"; the indicator itself is an obvious design choice among a finite set of conventions.
- Likely survivors: claim 4 ("audience layer operator") and possibly claim 13 (indicator-update-on-edit) — the only limitations with no clean of-record teaching. Everything else is vulnerable to a competently built combination.
- Practical note consistent with the earlier PTAB section: because § 103 is now a court/validity-contention question rather than an IPR question for this patent, the analysis above is what you would put in an invalidity contentions chart or a defensive invalidity opinion, not in a PTAB petition.
Confidence and limits. I am confident in the legal framework, in the § 103(c) disqualification, and in the disclosure content of O'Carroll and Turner (verified directly against their texts, including O'Carroll's [0103] multi-language passage and [0157] session-object passage) and of Spragins and Singh (verified via the ACM abstracts/abstract-recovery sources). I am less certain about the detailed figures of Motive '898, Ming Zhou, Kanie, and Lifefiles — I was cut off before verifying those page-by-page, so treat their specific mappings as provisional. The single biggest factual gap in any invalidity position built only on the of-record art is the absence of a reference that squarely teaches a per-field, user-visible inheritance indicator in an editor; that gap is where the patent lives, and closing it likely requires art outside the "Prior Art" section (e.g., contemporary GUI property-sheet / configuration-inheritance conventions).
Generated 10/1/2026, 11:31:53 AM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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