MasterCard International Incorporated

Patent Trials and Appeals Board

May 4, 2021

2020006224 (P.T.A.B. May. 4, 2021)

UNITED STATES PATENT AND TRADEMARK OFFICE
UNITED STATES DEPARTMENT OF COMMERCE
United States Patent and Trademark Office
Address: COMMISSIONER FOR PATENTS
P.O. Box 1450
Alexandria, Virginia 22313-1450
www.uspto.gov
APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO.
15/146,971 05/05/2016 Steven Charles DAVIS 0076412-000592 6616
125578 7590 05/04/2021
MASTERCARD
C/O Buchanan Ingersoll & Rooney PC
1737 King Street, Suite 500
Alexandria, VA 22314-2727
EXAMINER
JAMI, HARES
ART UNIT PAPER NUMBER
2162
NOTIFICATION DATE DELIVERY MODE
05/04/2021 ELECTRONIC
Please find below and/or attached an Office communication concerning this application or proceeding.
The time period for reply, if any, is set in the attached communication.
Notice of the Office communication was sent electronically on above-indicated "Notification Date" to the
following e-mail address(es):
ADIPDOC1@BIPC.com
charles.wieland@bipc.com
PTOL-90A (Rev. 04/07)
UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE PATENT TRIAL AND APPEAL BOARD
Ex parte STEVEN CHARLES DAVIS
Appeal 2020-006224
Application 15/146,971
Technology Center 2100
Before CAROLYN D. THOMAS, MICHAEL J. STRAUSS, and
PHILLIP A. BENNETT, Administrative Patent Judges.
BENNETT, Administrative Patent Judge.
DECISION ON APPEAL
STATEMENT OF THE CASE
Pursuant to 35 U.S.C. § 134(a), Appellant1 appeals from the
Examiner’s decision to reject claims 1–4, 6–14, and 16–20. Claims 5 and 15
are cancelled. We heard argument on April 14, 2021. A transcript will be
placed in the record in due course. We have jurisdiction under
35 U.S.C. § 6(b).
We affirm.

1 “Appellant” refers to “applicant” as defined in 37 C.F.R. § 1.42(a).
Appellant identifies the real party in interest as Mastercard International
Incorporated. Appeal Br. 2.
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CLAIMED SUBJECT MATTER
Appellant’s invention relates to the generation and management of
unique primary key values for data stored in a database. The Specification
describes that database records often have associated primary keys that are
intended to uniquely identify a record in a table and/or database. Spec. ¶¶ 2–
4. For example, a database might have a “CITIES” table that includes
several records (“Washington,” “Alexandria,” “Arlington”). Each record is
given a primary key value that uniquely identifies that record in the
database—for example, the primary key value could be assigned as
consecutive numbering:
CITIES
Primary Key Value Data Value
1 Washington
2 Alexandria
3 Arlington

The Specification explains that the problem with such a scheme is that
these types of primary keys are not unique across tables and databases.
Spec. ¶ 3. That is, another table in the same database, or even tables in other
databases, may use the same primary key values to identify other, different
database records. Spec. ¶ 3. As a result, combining data and sharing data is
made more difficult:
For example, two companies may have a need to exchange sets
of documents stored in internal storage. Each company may use
the same numbering system for identification, which may result
in multiple documents having conflicting identifiers. As a result,
either the documents must be stored in separate tables and/or
databases, or identifiers must be modified for one or both of the
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sets. In the former instance, it may be difficult to make
adjustments to both tables/databases at once and may be
inconvenient for the purposes of sorting and storage. In the latter
instance, the two parties must both agree on the alternative
identification with one or both parties modifying their previous
identification system accordingly, which can be highly
inconvenient and potentially detrimental due to the prevailing
use of the identifiers in the rest of their business.
Spec. ¶ 4.
Appellant’s invention seeks to address this issue by using a “collision-
resistant” hash algorithm, such as an SHA-256 algorithm, to generate
primary key values that are always unique to the particular data value
associated with each record. According to the Specification, “[t]he use of
collision-resistant hashing to develop identification values for disparate data
sets may enable the combination of data sets without collisions and may
preserve integrity of the data sets and their identification following any
future combination of additional data sets into the universal data storage.”
Spec. ¶ 6.
In the claimed embodiments, a hash algorithm is run against the data
to generate a hash value, which in turn becomes the primary key value for
that data record. Spec. ¶ 22. If an appropriate hash algorithm is used then,
in the unlikely event that two different data records hash to the same primary
key value, the resultant conflict (termed as “collision”) may be resolved
using a number of techniques including by defining a new hash algorithm
and re-hashing the data records. When necessary, the hash-generated
primary key values can be updated by defining a new hash algorithm, and
re-hashing the data records. When updates occur, the key value is updated,
but the data value always remains unchanged.
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Claim 1, reproduced below, is illustrative of the claimed subject
matter:
1. A method for generating a universal distributed data
storage, comprising:
receiving, by a receiving device of a processing server, a
data signal superimposed with a plurality of data values;
generating, by a hashing module executed by a processor
of the processing server, a key for each of the plurality of data
values, wherein the respective key is generated via application of
a hashing algorithm to the associated data value;
executing, by a querying module executed by the
processor of the processing server, a first query on a key-value
database of the processing server to store each of the plurality of
data values and the associated generated key as a plurality of key-
value pairs, where the generated key is a key in the key-value
pair and where the data value is a value in the key-value pair;
receiving, by the receiving device of the processing server,
a data signal superimposed with a plurality of additional key-
value pairs, wherein each value of the plurality of additional key-
value pairs is not included in the plurality of data values;
executing, by the querying module of the processing
server, a second query on the key-value database of the
processing server to store each of the plurality of additional key-
value pairs;
receiving, by the receiving device of the processing server,
a data signal superimposed with a rehash request, wherein the
rehash request indicates a different hashing algorithm;
generating, by the hashing module of the processing
server, a new key for each of the plurality of data values and each
value included in the plurality of additional key-value pairs via
application of the different hashing algorithm to the respective
data value; and
executing, by the querying module of the processing
server, a third query on the key-value database of the processing
server to replace the generated key in each of the plurality of key-
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value pairs with the new key generated for the respective key-
value pair, and to replace a key in each of the plurality of
additional key-value pairs with the new key generated for the
respective additional key-value pair without replacing the value
in each of the plurality of key-value pairs and the plurality of
additional key-value pairs, wherein each key included in the
plurality of additional key-value pairs is generated via
application of the hashing algorithm to the associated value and
is not included in the keys generated for each of the plurality of
data values.
Appeal Br. (Claims Appendix 1–2).
REFERENCES2
The prior art relied upon by the Examiner is:
Name Reference Date
Loeb US 2006/0271539 A1 Nov. 30, 2006
Hunt US 2013/0268770 A1 Oct. 10, 2013
Jin US 2014/0019680 A1 Jan. 16, 2014
Zhang US 2015/0293937 A1 Oct. 15, 2015
Brosch US 2016/0162508 A1 June 9, 2016
REJECTIONS
Claims 1, 9–11, 19, and 20 are rejected under 35 U.S.C. § 103 as
being unpatentable over Loeb, Zhang, and Hunt. Final Act. 6–10.
Claims 2, 3, 6, 7, 12, 13, 16, and 17 are rejected under 35 U.S.C.
§ 103 as being unpatentable over Loeb, Zhang, Hunt, and Brosch. Final
Act. 11, 12–13.
Claims 4, 8, 14, and 18 are rejected under 35 U.S.C. § 103 as being
unpatentable over Loeb, Zhang, Hunt, and Jin. Final Act. 11, 13–14.

2 All citations herein to the references are by reference to the first named
inventor/author only.
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ANALYSIS
Appellant’s arguments are made exclusively to claim 1, which we
treat as representative. Our decision as to claim 1 is, therefore, dispositive
as to the rejections of the remaining claims.
Claim 1 stands rejected under § 103 as obvious over Loeb, Zhang, and
Hunt. The Examiner finds that Loeb teaches most of the limitations (Final
Act. 6–9), which Appellant does not dispute (see Appeal Br. 9–13, which
focuses solely on the deficiencies of Hunt). The dispute, therefore, centers
primarily on Hunt—and whether it teaches or suggests the re-hashing
process recited in the claim.
In rejecting claim 1, the Examiner relies on Hunt as teaching:
a third query on the key-value database of the processing server
to replace the generated key in each of the plurality of key-value
pairs with the new key generated for the respective key-value
pair, and to replace a key in each of the plurality of additional
key-value pairs with the new key generated for the respective
additional key-value pair without replacing the value in each of
the plurality of key-value pairs and the plurality of additional
key-value pairs.
Final Act. 8–9 (emphasis omitted) (citing Hunt ¶ 112, Fig. 22). Specifically,
the Examiner finds that Hunt teaches “that an old hash value of a hash key is
replaced with a new hash value through probing the hash table while the
given key (i.e. data value) is intact.” Id. at 9.
Appellant argues that Hunt is deficient because replacing of the “hash
value” in Hunt is an entirely different approach as compared to replacing the
“key” in claim 1. Appeal Br. 10. More specifically, Appellant argues:
As set forth above, the Office contends that the “hash
values” of Hunt are thereby equivalent to the “keys” of the
present claims. (See page 9 of the Final Office Action).
However, Hunt explicitly discloses that the values are being
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replaced in the hash table therein and not the keys. Hunt
explicitly recites that an old value is replaced with a new one
only if they have the same key. (See, for example, paragraph
[0112] of Hunt).
Conversely, the present claims explicitly recite that the
generated hash value is a key in a key-value pair, with the
underlying value used in the hash is the value in the key-value
pair. Additionally, the claims recite that a new hashing algorithm
is used with the same value to generate a new key, which then
replaces the key in the key-value pair.
Appeal Br. 10 (emphasis omitted). According to Appellant, the claimed
approach differs markedly from Hunt because it allows for the key to be
updated merely by sharing/applying a new hashing algorithm. Appeal
Br. 11.
The Examiner responds by explaining that although the terminology is
different in Hunt, in substance, the hash algorithm output is changed and the
hash input remains the same, which is what is recited in the claim. Ans. 4–5.
The Examiner further explains:
The Hunt reference discloses that an old hash value of a hash key
is replaced with a new hash value through probing the hash table
while the given key (i.e. data value) is intact (See Hunt: at least
paragraph 112 and Fig. 22). The features of “hash value” and
“key” disclosed by Hunt corresponds to limitation of “key” and
“value” (respectively) of the current claims. Thus, the feature of
replacing old hash values of hash keys with new values while the
given keys (i.e. data value) are the same as taught by Hunt would
generate pairs of hash value- key that the hash values have been
updated and the input data are the same.
Ans. 7.
We are not persuaded of reversible Examiner error. The disputed “re-
hashing” functionality uses a modified hash function to create a new hash
output for a given input. Although Appellant emphasizes that this approach
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is unique in the context of primary keys for database records, Appellant
acknowledges that Loeb teaches creating primary keys based on hash
outputs (which is not disputed by Appellant). See, e.g., Loeb Abstract (“A
method and system for storing data in a data storage area of a computer that
utilizes hashing functions to avoid collision of new data records with
existing data records.”). Loeb further evidences that the use of hash
algorithms for the purpose of avoiding and/or obviating the effects of
collisions was known. See, e.g., Loeb ¶ 19 (“a second hashing algorithm for
determining a new target slot for the new data record if the new data record
collides with a stored data record”).
Hunt demonstrates that it was generally known in the art to update
hash values (i.e., hash outputs) by updating the hash function/algorithm
applied to the hash input. See Hunt ¶ 112. Hunt’s terminology differs from
the terminology set forth in the claims. However, the process described in
Hunt involves modifying the hash output (referred to as the “value” in a hash
table) by changing the algorithm applied to the same input (referred to as the
“given key”) throughout the records of a given hash table. That is, Hunt
teaches, in the context to data management, that hash outputs for a given
record store may be modified while maintaining hash inputs by applying a
different hashing function.
As such, we agree with the Examiner that a person of ordinary skill in
the art would have found it obvious to update Loeb’s primary keys upon
receiving a rehashing request by applying an updated hash function to
produce a different hash output for Loeb’s records in a database table, as
taught by Hunt. Therefore, we are not persuaded the Examiner erred in
rejecting claim 1 under § 103.
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CONCLUSION
We affirm the Examiner’s decision to reject the claims.
DECISION SUMMARY
Claim(s)
Rejected
35 U.S.C.
§
Reference(s)/Basis Affirmed Reversed
1, 9–11, 19,
20
103 Loeb, Zhang, Hunt 1, 9–11, 19,
20

2, 3, 6, 7,
12, 13, 16,
17
103 Loeb, Zhang,
Hunt, Brosch
2, 3, 6, 7,
12, 13, 16,
17

4, 8, 14, 18 103 Loeb, Zhang,
Hunt, Jin
4, 8, 14, 18
Overall
Outcome
1–4, 6–14,
16–20

TIME PERIOD FOR RESPONSE
No time period for taking any subsequent action in connection with
this appeal may be extended under 37 C.F.R. § 1.136(a). See 37 C.F.R.
§ 1.136(a)(1)(iv).
AFFIRMED