Judge Orrick construed 19 terms from seven patents relating to methods for allowing software to interact with relational databases in Thought, Inc. v. Oracle Corp., No 12-05601 (N.D. Cal. October 22, 2014). The court adopted the plaintiffs’ proposed constructions nearly without exception. Broadly speaking, the court seemed to feel that Oracle was attempting to insert unnecessary limitations into its proposed constructions. The court also seemed unpersuaded by Oracle’s expert testimony regarding the understanding of a person of ordinary skill, particularly where the court felt that there were adequate disclosures in the intrinsic evidence to supply a definition of a term.
Oracle also argued that a number of claims were indefinite. After first determining that it was Oracle’s burden to show indefiniteness by “clear and convincing” evidence, the court declined to find any of the terms indefinite. In particular the court construed the following terms:
1. “extensive knowledge” As used in the claims, the court found that a person of ordinary skill would understand the limitation imposed by the term. For example, the term is used in one claim as follows: “the mapping system portion provides an interface . . without requiring the user to have extensive knowledge of a particular relational database as a source of the data, or extensive knowledge about how to directly access that relational database.” Judge Orrick was receptive to Thought’s expert’s opinion that a “person of ordinary skill in the art would understand the term ‘extensive knowledge’ of a particular relational database or how to directly access that relational database, to mean ‘knowledge of the schema and query language sufficient to save or retrieve data’.”
2. “the mapping system portion is designed to provide to a system user who is accessing, creating or updating maps, or accessing objects on a system to make data changes related to a particular object and to . . .” Oracle argued that the “thing” being provided to a system user is missing and, therefore, the claim is indefinite. Oracle argued further that Thought’s definition, which inserted “the ability” after the phrase “to provide” was an impermissible attempt to correct an incomplete phrase or drafting error in patent. The court stated that its construction did not “correct an ‘error’ [but] is instead a construction clarifying the awkward language of the claim and a construction that flows directly from the text of the claims themselves.”
3. “object” The term “object” appeared in several of the asserted patents. The court found that each of the patents provided enough information to render the term sufficiently definite in context.
4. “model” Oddly, Oracle argued both that the term was expressly defined in the specification, and that the term was indefinite. The court adopted the definition proposed by Thought, which reflected the definition in the claims.
5. “changes to a CDO or its relationship of a CDOG model” Oracle argued that the term was both internally illogical, and that “something is missing” from the claim language (presumably because of a mistake by the patent drafter).
6. “the information of (a)” The court determined that this element referred back to a preceding element (a) in the patent claims.
7. “wherein repository maps are organized according to at least one navigation model or schema” Oracle asserted that because “repository maps” and “navigational models” or “navigations schemas” play no defined role in furthering the purpose of the claim or the invention, and because “repository maps has no generally understood meaning in the art,” the terms are indefinite. The court found “that the purpose and role of repository maps are adequately defined and explained in the specification.”
Finally, Oracle asserted that six claims were invalid under section 112(f) for failing to disclose sufficient structure to perform the claimed function. The court found that only one of the six “means-plus-function” claims failed to adequately disclose the accompanying structure.