InfoTrack Pty Limited v Encompass Corporation Pty Ltd
[2018] APO 16
•1 March 2018
IP AUSTRALIA
AUSTRALIAN PATENT OFFICE
InfoTrack Pty Limited v Encompass Corporation Pty Ltd [2018] APO 16
Patent Application: 2013201921
Title:Information displaying method and apparatus
Patent Applicant: Encompass Corporation Pty Ltd
Opponent: InfoTrack Pty Limited
Delegate: Dr S. J. Smith
Decision Date: 1 March 2018
Hearing Date: Written submissions completed on 20 November 2017
Catchwords: PATENTS – opposition under section 104 – allowability under section 102(1) and 102(2)(b) considered – opposition unsuccessful – amendment allowed – costs awarded against the opponent
Representation: Counsel for the applicant: David Shavin QC
Solicitor for the applicant: Gilbert + Tobin Lawyers
Patent attorney for the opponent: Shelston IP
IP AUSTRALIA
AUSTRALIAN PATENT OFFICE
Patent Application: 2013201921
Title:Information displaying method and apparatus
Patent Applicant: Encompass Corporation Pty Ltd
Date of Decision: 1 March 2018
DECISION
The opposition is unsuccessful. The proposed amendments comply with s 102(1) and s 102(2)(b) and I allow the amendments.
I award costs according to Schedule 8 against InfoTrack Pty Limited.
REASONS FOR DECISION
Background
Patent application 2013201921 was filed by Encompass Corporation Pty Ltd (Encompass) on 25 March 2013. The application was advertised as accepted on 17 March 2016.
A notice of opposition to the grant of the patent was filed by InfoTrack Pty Limited (InfoTrack) on 17 June 2016 and Evidence in Support was filed on 30 November 2016. Evidence in Answer has not yet been filed.
Encompass filed a request to amend the specification on 28 February 2017 which was withdrawn at the same time as filing a further request to amend the specification on 10 April 2017. Leave to amend was advertised on 15 June 2017. InfoTrack filed a Notice of Opposition to the allowance of the amendments on 15 August 2017.
The opposition
InfoTrack filed a statement of grounds and particulars on 15 September 2017, specifying grounds of opposition that the proposed amendments are not allowable because they do not comply with s 102(1) and s 102(2)(b).
The matter was heard by way of written submissions which were completed on 20 November 2017.
Two innovation patents claiming divisional status from the present application, patents 2014101164 and 2014101413, are presently the subject of Federal Court proceedings,[1] and in submissions the parties made references to evidence and submissions made in that proceeding.[2] InfoTrack also referred to evidence filed in support of the opposition to the grant of this application.[3] However, no evidence was filed in the present opposition to the amendments and I have not found the submissions based on portions of evidence divorced from their context to be of assistance.
[1] NSD 1689 of 2015.
[2] Encompass’ submissions filed on 6 November 2017 at [27]-[31]; InfoTrack’s Submissions filed on 20 November 2017 at [0015].
[3] InfoTrack’s submissions filed on 20 November 2017 at [0018].
The legislation
Examination of the application was requested before 15 April 2013 and therefore substantive amendments to the Patents Act 1990 (the Act) brought about by the Intellectual Property Laws Amendment (Raising the Bar) Act 2012 do not apply to the present application.
Subsections 102(1) and 102(2) of the Act as they apply to the present application are as follows:
(1) An amendment of a complete specification is not allowable if, as a result of the amendment, the specification would claim matter not in substance disclosed in the specification as filed.
(2) An amendment of a complete specification is not allowable after the relevant time if, as a result of the amendment:
(a) a claim of the specification would not in substance fall within the scope of the claims of the specification before amendment; or
(b) the specification would not comply with subsection 40(2) or (3).
The “relevant time” for the purpose of s 102(2) is after the specification has been accepted (s 102(2A) of the Act). As the present specification has been accepted, the requirements of s 102(2) apply.
The applicable parts of s 40 of the Act as they apply to the present case are set out below:
(2) A complete specification must:
(a) describe the invention fully, including the best method known to the applicant of performing the invention; and
(b) where it relates to an application for a standard patent – end with a claim or claims defining the invention.
(3)The claim or claims must be clear and succinct and fairly based on the matter described in the specification.
The nature of the amendments
The amendment is directed to the introduction of the words “by querying remote data sources” into independent claims 1 and 19 and the corresponding consistory clauses. The nature of the amendments is clear from a marked up version of claim 1, as shown below:
1. A method of displaying information relating to one or more entities, the method including, in an electronic processing device:
a) generating a network representation by querying remote data sources, the representation including:i) a number of nodes, each node being indicative of a corresponding entity; and,
ii) a number of connections between nodes, the connections being indicative of relationships between the entities; and,b) causing the network representation to be displayed to a user;
c) in response to user input commands, determining at least one user selected node corresponding to a user selected entity by determining selection of a node in the network representation using a user input device;
d) determining at least one search to be performed in respective of the corresponding entity associated with the at least one user selected node by:i) determining an entity type of the at least one user selected entity;
ii) determining a number of available searches relating to the entity type of the at least one user selected entity;
iii) displaying a list of the number of available searches on the network representation; and,
iv) determining selection of at least one of the available searches by determining selection of one of the list of the number of available searches using a user input devicee) performing the at least one search to thereby determine additional information regarding the entity; and,
f) causing any additional information to be presented to the user.
Claim 19 is in substantially the same terms but defines an apparatus for displaying information relating to one or more entities. A marked up copy of the complete claim set as proposed to be amended is reproduced at Annex A.
The specification
Given that the assessment of s 102(1) requires consideration of the specification as filed, references to the specification relate to the originally filed specification unless otherwise specified.
The specification relates to a method and apparatus for displaying information, in particular information relating to one or more entities to provide business intelligence.[4] The description of the prior art indicates that there are many electronic data collections containing information about entities, but the specification indicates that having information provided across multiple different repositories makes identification and accessing of relevant information difficult.[5] The specification states that while there are existing federated search mechanisms for searching across multiple data sources and methods for determining and evaluating business networks, these approaches are not suited to identification of business related information across multiple data sources.[6] The specification notes difficulties with identifying the same entity across multiple data sources where there are inconsistencies and inaccuracies in the data.[7] De-duplication of records in a data collection is also identified as a problem.[8]
[4] Page 1, [0001].
[5] Page 1, [0003].
[6] Page 1, [0004]-[0005].
[7] Page 2, [0006]-[0008].
[8] Page 2, [0009].
Against this background, the specification states:
“In a first broad form the present invention seeks to provide a method of displaying information relating to one or more entities, the method including, in an electronic processing device:
a) generating a network representation, the representation including:i) a number of nodes, each node being indicative of a corresponding entity; and,
ii) a number of connections between nodes, the connections being indicative of relationships between the entities; and,b) causing the network representation to be displayed to a user;
c) in response to user input commands, determining at least one user selected node corresponding to a user selected entity;
d) determining at least one search to be performed in respective of the corresponding entity associated with the at least one user selected node;
e) performing the at least one search to thereby determine additional information regarding the entity; and,f) causing any additional information to be presented to the user.”[9]
An apparatus for carrying out this method is also disclosed.[10]
[9] Page 3, [0013].
[10] Page 6, [0033].
There are two steps of the method that involve searching – steps (a) and (e) – and the amendment only relates to step (a). InfoTrack in its submissions has referred to steps (a) and (b) together as “Stage 1”.
For the purpose of this decision it is necessary only to consider in detail the first step, relating to the generation of a network representation. The specification describes the method with reference to the Figures, and in particular states that:
“The network representation may be generated in any appropriate manner, but in one example this is achieved by having the electronic processing device ascertain information regarding entities and their relationships and then executing a predetermined procedure for generating the network representation. In this regard, the information can be determined in a number of ways depending on the preferred implementation, such as by examining internal data, or by querying one or more remote data sources, such as repositories of business information, including for example, company registers or the like.”[11]
[11] Page 8, [0051].
Subsequently it is stated that:
“Typically the first network representation is generated in response to a search process. In order to achieve this, the electronic processing system determines a search to be performed in response to user input commands. This can include, for example, having a user simply select a search from a list of available searches. Following this, the electronic processing device generates a search query in accordance with the determined search to be performed, with the search query being applied to a repository to determine details regarding a number of entities and relationships between the number of entities. This is then used to generate the first network representation.”[12]
[12] Page 11, [0063].
A specific example relating to the purchasing of reports from ASIC is described. The Graphical User Interface (GUI) depicted in Figures 8A (reproduced below) and 8B associated with this example “displays a data source list 802 allowing the user to select a data source 205 to be used, such as any one or more of a number of different databases”.[13]
Section 102(1)[13] Page 20, [0101].
It is well established that the test for whether matter is in substance disclosed is similar to that used to assess fair basis.[14] The High Court in Lockwood Security Products Pty Ltd v Doric Products Pty Ltd[15] approved the approach to fair basis set out by Gummow J in Rehm Pty Ltd v Websters Security Systems (International) Pty Ltd:
“the question is whether there is a real and reasonably clear disclosure in the body of the specification of what is then claimed, so that the alleged invention as claimed is broadly, that is to say in a general sense, described in the body of the specification.” [16]
[14] Ethyl Corporation’s Patent [1972] RPC 169; ICI Chemicals & Polymers Ltd v Lubrizol Corporation Inc [2000] FCA 1349; 106 FCR 214.
[15] [2004] HCA 58; (2004) 217 CLR 274.
[16] (1988) 81 ALR 79 at 95.
Accordingly, for an amendment to be allowable under s 102(1) there must be a real and reasonably clear disclosure of the claims as proposed to be amended in the specification as originally filed. This enquiry is limited, however, to the consequences of the amendment. That is, the amended claims must not, as a result of the amendment, be inconsistent with what the specification as originally filed describes as the invention.
As an initial point, InfoTrack submitted that the description provides that querying data sources is a means by which information is determined, following which a network representation is generated by execution of a predetermined procedure by an electronic processing device. Accordingly, to amend the claim such that the network representation is generated by querying data sources (as opposed to the predetermined procedure) would result in the claim being inconsistent with the specification as filed.[17] Considering the claims as proposed to be amended in the context of the specification, I do not understand “generating a network representation by querying remote data sources” to mean that the querying of remote data sources is the only step in the generation of the network representation, rather, I understand this to be a step in a process the result of which is generation of the network representation, and as such, I do not consider that the amendment results in an inconsistency with the specification as filed for this reason.
[17] InfoTrack’s submissions filed 6 November 2017 at [0017].
As will become clear, the construction of “by querying remote data sources” is important to the parties’ arguments, specifically the question of whether this includes or excludes the querying of a single data source. Encompass submitted that it “refers, in its natural meaning, to a query of one or more remote data sources.”[18] InfoTrack considers that querying of a single data source is excluded.[19] The parties made submissions regarding the construction adopted in Federal Court proceedings relating to divisional innovation patents of the present application.[20] In particular, Encompass submitted that InfoTrack’s approach in this proceeding is contradictory to that it adopted in the Court proceedings.[21] However, I do not have the expert evidence relied on in those proceedings before me, or indeed any evidence as to the construction of the claims. While Encompass excerpted portions of the evidence from the Federal Court proceedings in its submissions, as isolated passages in the absence of contextual information these are not of assistance.
[18] Encompass’ submissions filed 6 November 2017 at [25].
[19] For example, InfoTrack’s submissions filed 6 November 2017 at [0041]-[0042].
[20] Encompass’ submissions filed 6 November 2017 at [28]-[31]; InfoTrack’s submissions filed 20 November 2017 at [0015].
[21] Encompass’ submissions filed 6 November 2017 at [32]-[33].
I will approach construction of the phrase in the normal way.[22] The phrase refers to sources, that is, the plural of source. The description provides no definitions or indication that for the purpose of the specification words in the plural also include the singular. In the absence of evidence as to the construction of the term in context, I will adopt the plain meaning. I disagree with Encompass as to the plain or natural meaning of remote data sources. Expression of a noun as a plural conventionally means greater than one of said noun. Such an approach in this instance does not lead to an absurd result, and recourse to the specification does not, in my view, mandate an alternate construction. Indeed, the specification refers on multiple occasions to “one or more”, which clearly indicates that singular or plural is intended, including in relation to remote data sources. The use of a different form of words in the claim, while not in itself conclusive, is suggestive of a different meaning. Encompass referred to the reference to a single repository in appended claim 10 in support of its construction, but as I will discuss below, I do not find this, in itself, to be conclusive. Therefore, in the absence of any expert evidence as to the meaning of the phrase in context, I will adopt the plain meaning of the claim and proceed on the basis that the claim as amended requires querying of more than one remote data source.
[22] H Lundbeck A/S v Alphapharm Pty Ltd [2009] FCAFC 70; 81 IPR 228 at [118]-[120]; Décor Corporation Pty Ltd v Dart Industries Inc [1988] FCA 399; (1998) 13 IPR 385 at 400.
InfoTrack’s main submission in relation to s 102(1) is that the amendment, while narrowing, changes the nature of the invention as described in the specification. Specifically:
“the Applicant is seeking to disclaim from all the claims the following features:
· Querying a single data source in Stage 1.
· Querying a local data source in Stage 1.
However, to do so is to propose to change the nature of the invention as obtained from a reading of the specification as a whole and as claimed in the specification as filed. … the problems identified in the specification concerning the prior art, and the promise of the invention, relate to single and multiple data sources. The example of the invention described with reference to the Figures frequently, primarily and predominantly makes use the applicability of the single example of the invention (see paragraph [0034] of the patent specification) to a single local data source, and a single remote data source. Accordingly, to propose to disclaim the features referred to in paragraph [0043] of this document is to propose to curtail the claims such that they are not able to deliver upon the promise of the patent specification and which exclude from those claims the single example of the invention described in the specification.”[23]
[23] InfoTrack’s submissions filed 6 November 2017 at [0041]-[0042].
InfoTrack cited the decision of the Full Court in AstraZeneca AB v Apotex Pty Ltd (AstraZeneca)[24] (in the context of determining the priority date of a claim under s 114) as supportive of the view that a narrowing amendment of this type gives rise to a lack of fair basis. In AstraZeneca claims were directed to a pharmaceutical composition comprising rosuvastatin or a pharmaceutically acceptable salt thereof and an inorganic salt in which the cation is multivalent. The claims were amended to exclude inorganic salts where the counter anion is a phosphate. The Full Court observed that while the compositions claimed as a result of the amendment were disclosed in the specification as filed, and there was nothing to suggest that use of phosphate as a counter ion was essential, di- and tri-basic calcium phosphate were stated in the specification to be preferred inorganic salts, and tribasic calcium phosphate was the inorganic salt used in each of the examples. The Court therefore found that the amended form of the claims was “fundamentally inconsistent” with the specification before amendment.[25] InfoTrack pointed particularly to the statement of the majority:
“Not only does the specification before amendment not suggest that phosphate not be used as the counter anion in the organic salts used in the pharmaceutical compositions of the invention, it positively recommends that it be used for that purpose. We are satisfied that the unamended specification does not contain a real or reasonably clear disclosure of what was claimed as a result of the 2005 amendments.”[26]
[24] [2014] FCAFC 99; 107 IPR 177.
[25] [2014] FCAFC 99; 107 IPR 177 at [245]-[247].
[26] [2014] FCAFC 99; 107 IPR 177 at [247].
In InfoTrack’s submission this decision is directly applicable to the present circumstances; the specification positively recommends the use of a local data source and a single data source.[27] That is, the specification is directed to a single invention relating to the display of information, and “any attempt to exclude the capacities or configurations of the data sources from the claims is to change the nature of the invention being claimed”.[28]
[27] InfoTrack’s submissions filed 6 November 2017 at [0046], [0049].
[28] InfoTrack’s submissions filed 20 November 2017 at [005].
In addition to AstraZeneca, InfoTrack referred to the ‘Mond Nickel rules’ as recited in Leonardis v Sartas No 1 Pty Ltd[29] - in summary, whether the claimed invention is broadly described in the specification and whether there is anything in the specification that is inconsistent with the claimed invention. In relation to these tests InfoTrack submitted that “the only technical solutions provided in the patent specification are equally applicable to a local data source, local data sources, a remote data source, and remote data sources” and that there is no suggestion that the use of any of these sources separately constitutes an invention.[30] InfoTrack also submitted that limitation of the claimed invention as proposed would be inconsistent with statements in the specification, some of which I will discuss in more detail below, and that given that the problem the application is directed to solving (i.e. de-duplication of data records) is not related to the data source, the amendment would result in the claims addressing only part of the problem, or a different problem, and would be inconsistent with the specification on that basis.[31] The basic thrust of InfoTrack’s submission is that the querying of single and multiple local and remote data sources are “not separate inventions but separate capacities of the same invention”.[32]
[29] [1996] FCA 449; (1996) 67 FCR 126.
[30] InfoTrack’s submissions filed 20 November 2017 at [007].
[31] InfoTrack’s submissions filed 20 November 2017 at [009]-[0011].
[32] InfoTrack’s submissions filed 20 November 2017 at [0012].
Encompass submitted that (i) the claim as amended encompasses querying a single remote data source and (ii) the specification discloses two inventions – one in which a local search is undertaken and one in which a remote data search is undertaken.[33] Accordingly, in Encompass’ submission the amendment results in a claim to the latter of these inventions. As noted above I do not agree with Encompass’ construction of the claims as proposed to be amended.
[33] Encompass’ submissions filed 6 November 2017 at [16], [25].
Encompass referred to the decision of the Full Court in Kimberly-Clark Australia Pty Limited v Multigate Medical Products Pty Limited, in which it is made clear that a claim may be more limited in scope than any particular embodiment described in the specification, provided that it is fairly based.[34] There is no additional requirement that I know or that InfoTrack has pointed me to that where a problem is broadly posited and solved in multiple ways all disclosed means must be claimed. The question to be considered is whether the limitation of the claimed method and apparatus to querying multiple remote data sources (and accordingly exclusion of querying a single data source and querying a local data source) results in a lack of fair basis.
[34] [2011] FCAFC 86; 92 IPR 21 at [44].
InfoTrack submitted that the example of the invention accommodates querying of a single data source and there is no example of the invention that does not.[35] InfoTrack referenced numerous passages referring to a single data source,[36] and I agree that it is clear that querying of a single remote data source is exemplified. InfoTrack also referred to the reference in originally filed claim 13 (which is in the same terms as accepted claim 10) to querying “a repository” as consistent with a strong and positive recommendation that a single data source be queried in Stage 1.[37] However, the examples clearly also refer to the querying of multiple data sources. For instance, Figure 2 (reproduced below) includes multiple data sources 205[38] and Figure 8A presents a data source list allowing for user selection of one or more data sources.[39] The facts of this case are distinguished from AstraZeneca at least in this regard. In the presence of exemplification of the querying of multiple data sources and the general reference to the querying of “one or more [emphasis added]” remote data sources in the specification, I consider that this can be reasonably understood as an embodiment of the invention for which there is a real and reasonably clear disclosure.
[35] InfoTrack’s submissions filed 6 November 2017 at [0047].
[36] InfoTrack’s submissions filed 6 November 2017 at [0020]-[0022], [0026]-[0031].
[37] InfoTrack’s submissions filed 6 November 2017 at [0048].
[38] Page 13, [0069].
[39] Page 20, [0101].
InfoTrack also submitted that it is clear that querying a local data source must be accommodated by the invention, particularly referring to the statement in the specification that “the process could be performed on a stand alone computer system.”[40] In InfoTrack’s submission such a system would necessitate the use of a local or internal data source and accordingly amendment to exclude that capacity is not allowable.[41] However, in my view, this supports Encompass’ submission that the sources to be queried are presented in the specification as alternatives – that is, if a standalone computer system necessitates querying a local data source, it precludes querying a remote data source. This is consistent with the general reference to the determination of information “by examining internal data, or by querying one or more remote data sources [emphasis added]”.[42]
[40] Page 14, [0076].
[41] InfoTrack’s submissions filed 6 November 2017 at [0050].
[42] Page 8, [0051].
InfoTrack also referred to the following passage in the specification:
“For the purpose of this example, an overview is described with respect to the purchasing of reports from ASIC (Australian Securities and Investments Commission), but it was be appreciated that this is not intended to be limiting and in practice any data source can be used [InfoTrack’s emphasis].”[43]
In InfoTrack’s submission it would be inconsistent with this passage for a claim to exclude any data source, be it local or remote.[44] However, I do not consider that to be a fair reading of the passage. In my view this passage means that, as it says, any data source can be used in the method. I do not agree that the fair corollary of this is that limiting the invention claimed to a chosen data source results, of necessity, in a claim to matter not in substance disclosed.
[43] Pages 19-20, [0100]; InfoTrack’s submissions filed 6 November 2017 at [0026].
[44] InfoTrack’s submissions filed 6 November 2017 at [0027].
I am satisfied that the specification provides a real and reasonably clear disclosure of the process involving the querying of remote data sources as an alternative to local data sources.
In summary, having considered the parties’ submissions I do not think that a fair reading of the specification requires in all embodiments of the invention that local, remote, single and multiple data sources must all be queried or be under active consideration for querying for the determination of information for the generation of a network representation. I conclude that the specification describes these as options which may be used in the invention. Accordingly, the amendment limiting the invention to the embodiment of querying multiple remote data sources does not result in a claim to matter not in substance disclosed in the specification as filed. InfoTrack has not established that the amendment does not comply with s 102(1).
Section 102(2)(b)
InfoTrack submitted that the amendment is not allowable under s 102(2)(b) as the amendment would result in a failure of the claims to comply with s 40(3) with regard to clarity and fair basis.
Clarity
It is a requirement of s 40(3) of the Act that the claims be clear. This requirement is satisfied if a person could ascertain “whether or not what he proposes to do falls within the ambit of the claim”.[45] When construing claims a “generous measure of common sense should be used”.[46]
[45] Monsanto Co v Commissioner of Patents (1974) 48 ALJR 59 at 60.
[46] Product Management Group Pty Ltd v Blue Gentian LLC [2015] FCAFC 179 at [36].
InfoTrack submitted that the claims lack clarity as a result of the amendment, asserting an inconsistency between claim 10 and claim 1 as proposed to be amended.
Claim 10 as accepted reads:
10. A method according to any one of the claims 1 to 9, wherein the method includes:
a) in response to user input commands, determining a search to be performed;
b) generating a search query in accordance with the determined search to be performed; the search query being applied to a repository to thereby determine details regarding:
i) a number of entities; and,
ii) relationships between the number of entities; and,
c) using the details to generate the network representation.In InfoTrack’s submission the reference to the search query being applied to a (single) repository results in claim 10 being inconsistent with the requirement in claim 1 as proposed to be amended that (multiple) remote data sources be queried.[47]
[47] InfoTrack’s submissions filed 6 November 2017 at [51], [55].
I do not agree with InfoTrack’s submission. Claim 10 is appended to claim 1 and therefore should be understood in that context – that is, it defines a method according to claim 1. As discussed above, I have construed claim 1 as proposed to be amended to require that multiple data sources are queried. Claim 10 refers to “the search query being applied to a repository”, however, while the claim defines the application of the query to a repository, in my view it does not exclude or mandate against querying of a further repository. Accordingly, adopting a common sense approach claim 10 can be meaningfully understood as dependent on and consistent with claim 1. I am therefore not satisfied that the proposed amendment results in a lack of clarity.
Fair basis
InfoTrack’s argument in relation to this ground is effectively the same as that made in relation to s 102(1) and I have discussed above the similarity between the tests for s 102(1) and fair basis. While the description as originally filed is not identical to the description as accepted, the changes do not relate to exemplification or detailed description of the invention and so for the reasons given in relation to s 102(1) I am satisfied that the amendment does not result in a lack of fair basis.
Conclusion
InfoTrack has not established that the amendment does not comply with s 102(2)(b).
Conclusion
The opposition is unsuccessful. The proposed amendments are allowable.
Costs
Ordinarily in proceedings such as these, costs follow the event and having considered the parties submissions in relation to costs I do not see any reason to depart from this approach. I will award costs against InfoTrack.
Dr S. J. Smith
Delegate of the Commissioner of Patents
Annex A1) A method of displaying information relating to one or more entities, the method including, in an electronic processing device:
a) generating a network representation by querying remote data sources, the representation including:
i) a number of nodes, each node being indicative of a corresponding entity; and,
ii) a number of connections between nodes, the connections being indicative of relationships
between the entities; and,
b) causing the network representation to be displayed to a user;
c) in response to user input commands, determining at least one user selected node corresponding to a user selected entity by determining selection of a node in the network representation using a user input device;
d) determining at least one search to be performed in respective of the corresponding entity associated with the at least one user selected node by:
i) determining an entity type of the at least one user selected entity;
ii) determining a number of available searches relating to the entity type of the at least one
user selected entity;
iii) displaying a list of the number of available searches on the network representation; and,
iv) determining selection of at least one of the available searches by determining selection of one of the list of the number of available searches using a user input device
e) performing the at least one search to thereby determine additional information regarding the entity; and,
f) causing any additional information to be presented to the user.
2) A method according to claim 1, wherein the method includes generating a search query, the search query being applied to a database to thereby determine additional information regarding the entity.
3) A method according to claim 1 or claim 2, wherein the additional information includes details of entities related to the at least one user selected entity, and wherein the method includes generating a second network representation, the second network representation including:
a) a number of nodes, each node being indicative of a corresponding entity and the entities include the at least one user selected entity and at least one related entity; and,
b) a number of connections between the nodes, the connections being indicative of relationships
between the entities.
4) A method according to claim 3, wherein the method includes generating the second network representation by modifying the network representation.
5) A method according to claim 4, wherein the method includes modifying the network representation by adding one or more nodes corresponding to at least one related entity.
6) A method according to any one of the claims 1 to 5, wherein the method includes, in response to user input commands:
a) displaying a list of a number of available searches relating to the at least one user selected entity; and,
b) determining selection of at least one of the available searches in accordance with user input commands.
7) A method according to any one of the claims 1 to 6, wherein the method includes generating a search query using at least one of:
a) predefined rules; and,
b) a predefined script.
8) A method according to claim 7, wherein the method includes:
a) determining if further search parameters are required to generate the search query;
b) in response to a successful determination, causing required parameters to be displayed to a user; and,
c) determining the required parameters in response to user input commands.
9) A method according to any one of the claims 1 to 8, wherein the method includes:
a) in response to user input commands, determining at least one manipulation of a network representation; and,
b) generating a manipulated network representation in accordance with user input commands.
10) A method according to any one of the claims 1 to 9, wherein the method includes:
a) in response to user input commands, determining a search to be performed;
b) generating a search query in accordance with the determined search to be performed; the search query being applied to a repository to thereby determine details regarding:
i) a number of entities; and,
ii) relationships between the number of entities; and,
c) using the details to generate the network representation.
11) A method according to any one of the claims 1 to 10, wherein the method includes:
a) determining search results data indicative of additional information; and,
b) analyzing the search results data to identify at least one entity.
12) A method according to claim 1 1, wherein the method includes identifying at least one entity by at least one of:
a) pattern matching; and,
b) fuzzy logic.
13) A method according to claim 11 or claim 12, wherein the method includes identifying at least one
entity by at least one of:a) determining entity details from the search results data, the entity details including at least one of:
i) an entity name;
ii) an entity address; and,
iii) date of birth;
b) comparing the entity details to existing entity details for existing identified entities; and,
c) determining if the entity is one of the existing entities based on the results of the comparison.
14) A method according to claim 13, wherein the method includes:
a) modifying the entity details in accordance with at least one of:
i) defined misspellings; and,
ii) phonetic equivalents; and,
b) comparing modified entity details to the existing entity details.
15) A method according to claim 13 or claim 14, wherein the method includes:
a) determining a distance indicative of a difference between the entity details and existing entity details; and,
b) determining the entity as an existing entity based on the difference.
16) A method according to any one of the claims 11 to 15, wherein the search results data is in the form of
a mark-up data file and wherein the method includes:
a) determining a document definition; and,
b) determining entity details in the mark-up file using the document definition.
17) A method according to any one of the claims 1 to 16, wherein the method includes receiving the search results data via a communications network.
18) A method according to any one of the claims 1 to 17, wherein the method includes performing the at least one search by:a) determining search parameters required to perform the search;
b) causing the search parameters to be displayed to the user; and,
c) determining any required search parameters in response to user input commands; and,
d) generating a search query using the search parameter, the search query being used to perform the search.
19) Apparatus for of displaying information relating to one or more entities, the apparatus including, in an electronic processing device for:
a) generating a network representation by querying remote data sources, the representation including:
i) a number of nodes, each node being indicative of a corresponding entity; and,
ii) a number of connections between nodes, the connections being indicative of relationships between the entities; and,
b) causing the network representation to be displayed to a user;
c) in response to user input commands, determining at least one user selected node by determining selection of a node in the network representation using a user input device;
d) determining at least one search to be performed in respective of the corresponding entity associated with the at least one user selected node by:
i) determining an entity type of the at least one user selected entity;
ii) determining a number of available searches relating to the entity type of the at least one user selected entity;
iii) displaying a list of the number of available searches on the network representation; and,
iv) determining selection of at least one of the available searches by determining selection of one of the list of the number of available searches using a user input device;
e) performing the at least one search to thereby determine additional information regarding the entity; and
f) causing any additional information to be presented to the user.