Obviousness — US Patent US8131597

Obviousness Analysis of US Patent 8131597 under 35 U.S.C. § 103

This analysis evaluates whether the invention claimed in U.S. Patent 8,131,597 would have been obvious to a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention. The legal standard for obviousness under 35 U.S.C. § 103 holds that a patent claim is invalid if the differences between the claimed invention and the prior art are such that the subject matter as a whole would have been obvious to a PHOSITA. This analysis relies on the prior art references identified in the preceding section.

For the purpose of this analysis, a PHOSITA in June 1995 (the earliest priority date) would be an individual with a bachelor's degree in computer science or a related field, with practical experience in client-server architecture, computer networking protocols (including the nascent World Wide Web and HTTP), database management systems, and familiarity with common data-entry technologies such as barcode scanning.

Based on the available prior art, the independent claims of US8131597 appear to be obvious over at least two potential combinations of references.

1. Combination of Stumm (US 5,768,528) and Palmer (US 5,905,865)

A strong argument for obviousness can be made by combining the teachings of Stumm (US 5,768,528) with the teachings of Palmer (US 5,905,865).

What Stumm Teaches: Stumm discloses the core technical process central to the '597 patent. It teaches a system where a user machine-reads a barcode from a printed medium (a catalog) to obtain a product identifier (the "index"). This index is transmitted from the user's computer over a network to a vendor's remote server. The server uses this index to query a database and retrieve associated product information, which is then sent back to the user's computer to facilitate an online order. Stumm therefore teaches every step of the claimed method except for the specific nature of the retrieved information being a "pointer" (like a URL) used to access a general "remote information computer."
What Palmer Teaches: Palmer discloses a system for automatically accessing online resources (specifically, websites identified by URLs) that are broadcast in conjunction with television programming. The key teaching from Palmer is the utility and method of using a computer system to seamlessly connect a user to a specific online location (a website) to provide information that supplements other media, without requiring manual address entry.
Motivation to Combine: A PHOSITA in the mid-1990s, looking to improve upon Stumm's e-commerce catalog system, would have been motivated to combine it with the concepts taught by Palmer. The World Wide Web was rapidly emerging as a powerful medium for providing rich, dynamic, and interactive content far beyond the static product data and ordering forms described by Stumm. A PHOSITA would have recognized that the user experience in Stumm's system could be significantly enhanced.

The motivation would be to replace the retrieval of simple product/order data in Stumm's database with the retrieval of a URL pointing to a product's dedicated webpage. This webpage could contain marketing videos, detailed specifications, user manuals, and other information as contemplated by the burgeoning web, creating a more engaging and informative experience than a simple order form. This would have been a predictable and logical improvement.

Therefore, it would have been obvious to a PHOSITA to modify Stumm's system by having the database associate the scanned product ID ("index") with a URL ("pointer") to a remote information computer (a web server), as taught by Palmer. The combination of Stumm's barcode-to-database lookup mechanism with Palmer's concept of automated access to URL-based online resources renders the claims of US8131597 obvious.

2. Philyaw (US 6,098,106) as a Base Reference

The prior art analysis suggests that Philyaw is so closely related to the '597 patent that it might be anticipatory. However, if any narrow distinction exists, the claims would certainly be obvious in view of Philyaw.

What Philyaw Teaches: Philyaw discloses a complete system for linking a physical object to online information. It teaches providing a unique code ("index") on a product, which a user enters into a computer. The computer transmits this index to a server, which uses it to look up a corresponding network address ("pointer") and automatically links the user to that address. Philyaw's disclosure maps almost directly onto the process defined in independent claims 1, 12, 22, and 27 of the '597 patent.
Obvious Implementation: Assuming for the sake of argument that Philyaw's disclosure of "linking" the user does not explicitly detail the two-step process of the server returning the pointer to the client device, which then separately uses the pointer to initiate a new connection, this would have been an obvious implementation choice to a PHOSITA. The standard method for web-based redirection and linking at the time of the invention was for a server to respond to a client's request with a new URL (e.g., in an HTTP redirect header or as a hyperlink in an HTML document). The client's browser would then automatically or with user interaction make a new request to that URL.

Therefore, a PHOSITA tasked with building the system described by Philyaw would naturally and obviously implement it using the standard client-server communication protocols of the day, resulting in the exact process claimed by US8131597. The claimed method is merely a description of the standard and obvious way to implement the broader system and method already taught by Philyaw.