PTAB

CBM2014-00138

Facebook Inc v. Bascom Research LLC

Key Events

Petition

petition

Title: Method for Users of a Network to Provide Other Users with Access to Link Relationships Between Documents
Brief Description: The ’241 patent discloses a method for creating, storing, and sharing user-defined "link relationships" between "document objects" (e.g., web pages) on a network. The system stores these relationships in "link directories" and includes financial aspects, such as billing users for creating or accessing these directories.

Prior Art Relied Upon: Keller (Richard M. Keller et al., A Bookmarking Service for Organizing and Sharing URLs, published in Computer Networks and ISDN Systems (Sept. 1997)).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Keller, which discloses a web-based bookmarking service called "WebTagger," teaches every limitation of claim 78. Keller’s "memories" (personal or group-based repositories for URLs) were asserted to be the claimed "link directories." The "topical categories" within these memories, which group multiple web pages (the "document objects"), were argued to be the claimed "link relationships." Petitioner contended that Keller explicitly discloses enabling users to create these memories, populate them with categorized URLs, and allow other users to access them, thus anticipating the claim. The textual names of the categories (e.g., "Digital Documents & Libraries") were identified as the "link relationship attributes."

Prior Art Relied Upon: Keller (as above) and Miller (International Publication No. WO 00/17775).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Keller teaches the core functionalities of creating and sharing categorized link collections, as argued for claim 78. However, Keller does not explicitly teach billing or storing the link directories on servers. Miller, which discloses a system for creating collaborative user-defined "environments" or "groups," was argued to supply these missing elements. Miller expressly teaches charging users a fee for creating or joining these groups and discloses that these environments are stored on a web server coupled to the internet. The combination therefore rendered the claims obvious.
- Motivation to Combine: A POSITA would combine Miller's well-known business practice of charging for web services with Keller's system to generate revenue and defray the operational costs of providing the service. Furthermore, implementing Keller's system on a centralized server, as taught by Miller, was a predictable and beneficial design choice to facilitate easier access and sharing among users compared to storing data on individual computers.
- Expectation of Success: A POSITA would have had a high expectation of success, as combining a known billing model with a web-based information sharing system involved the application of known techniques to achieve predictable results.

Prior Art Relied Upon: Keller, Miller (as above), and Brown (Patent 5,941,947).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the combination of Keller and Miller renders the subject matter of claim 2 obvious, which adds "permitting sponsorship by a sponsoring user" to the method of claim 1. Keller’s "moderator" for a group memory was argued to meet this limitation. Dependent claim 24 further requires providing this "sponsoring user" with the capability to allow other users to populate the link directories. While Keller’s moderator controls the memory, Brown was introduced to explicitly teach this delegation of content-addition rights. Brown discloses a "system administrator" for a bulletin board system (BBS) who can granularly control access rights, including specifying which users can add messages to a folder.
- Motivation to Combine: A POSITA would be motivated to integrate Brown's access control features into the Keller/Miller system to enhance its functionality. This would provide the moderator (sponsoring user) with the flexibility to delegate the task of populating the directory to trusted users. This offloads administrative tasks, a benefit expressly recognized in Brown, thereby making the system more scalable and manageable.
- Expectation of Success: Implementing user-specific access controls in a networked information system was a well-understood and common practice, presenting no significant technical hurdles.

"Link Relationship": Petitioner argued for the construction "information identifying two document objects." This broad construction was asserted to align with the specification and was critical for mapping the term to Keller’s "topical categories," which inherently identify the multiple documents they contain, without importing a separate requirement that the relationship itself include a descriptive attribute.
"Link Directory": Petitioner proposed the construction "a directory of link relationships." This was central to equating the claim term with the "memory" disclosed in Keller, which functions as a repository for the topical categories (i.e., the link relationships).
"Sponsoring User": Petitioner proposed "a person or entity that is responsible for a link directory." This construction was intended to encompass the "moderator" role in Keller and the "system administrator" in Brown, both of whom are responsible for managing a shared data repository.

Petitioner requests institution of a covered business method patent review and cancellation of claims 1, 2, 4, 17, 24, 61, and 78 of the ’241 patent as unpatentable.