PTAB

CBM2015-00065

Amazon.com Inc v. C4caSTCom Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Community-Selected Content
  • Brief Description: The ’204 patent describes methods and systems for providing resources to participants over an electronic network. The core process involves maintaining a collection of resources, assigning points to individual resources based on participant access or ratings, and modifying the collection based on the assigned points to curate the most useful content.

3. Grounds for Unpatentability

Ground 1: Patent Ineligibility Under § 101 - Claims 1-26 are invalid under 35 U.S.C. § 101 for failing to claim patent-eligible subject matter.

  • Prior Art Relied Upon: This ground is based on § 101 and legal precedent (e.g., Alice Corp. v. CLS Bank), not prior art references.
  • Core Argument for this Ground: Petitioner argued that all challenged claims are directed to a patent-ineligible abstract idea and lack an inventive concept sufficient to transform them into a patent-eligible application. The argument followed the two-step framework from Alice.
    • Alice Step 1 (Abstract Idea): Petitioner asserted the claims are directed to the abstract idea of using information about consumer behavior to determine what content to offer. This was characterized as a fundamental, long-standing economic principle of tailoring supply to demand. Petitioner contended this concept is not tied to any specific technology and is analogous to mental processes humans can perform without a computer, such as the practice of "weeding" little-used books from a library collection based on checkout frequency. The petition argued that claim 1, which recites maintaining a collection, assigning points based on access, and modifying the collection, is a direct implementation of this abstract concept.
    • Alice Step 2 (Inventive Concept): Petitioner argued the claims fail to provide an inventive concept because they merely apply the abstract idea using generic, conventional computer components. The claims recite elements like a "computer-readable medium," an "electronic network," and general-purpose computer processing steps, none of which were novel or non-obvious at the time of the invention. Petitioner contended that simply appending these conventional steps to an abstract idea does not transform it into a patent-eligible invention. The argument emphasized that the claims do not require any specific algorithm, improve the functioning of the computer itself, or solve a problem unique to the internet. The claims were described as so broad as to preempt any use of the abstract idea of using consumer data to curate content on a computer network. Dependent claims were argued to add only minor, well-known variations (e.g., removing the lowest-rated resource) that do not supply an inventive concept.

4. Key Claim Construction Positions

  • "resources": Petitioner argued for construing the claim term "resources" as "content." This construction was asserted to be the broadest reasonable interpretation based on intrinsic evidence. Petitioner supported this by pointing to the patent's title ("Community-Selected Content"), the specification's repeated and interchangeable use of "resources" and "content" to describe the invention, and statements made by the applicant during prosecution that explicitly referred to the invention as managing a "collection of content." This construction was central to the argument that the claims are directed to the abstract idea of managing intangible information.

5. Key Technical Contentions (Beyond Claim Construction)

  • Eligibility for Covered Business Method (CBM) Review: A significant portion of the petition was dedicated to establishing that the ’204 patent is eligible for CBM review. Petitioner argued the patent met the two necessary criteria:
      1. It claims a method used in the practice of a financial product or service. The petition detailed how the specification describes using the claimed invention for financial activities such as pricing derivative instruments, predicting economic indicators, marketing, advertising, and making strategic business decisions.
      1. It is not a "technological invention." Petitioner contended the claims do not recite a novel or non-obvious technological feature, nor do they solve a technical problem with a technical solution. Instead, the claims recite only generic, well-known computer hardware and network components to implement a business method, which does not qualify for the technological invention exception.

6. Relief Requested

  • Petitioner requested that the Board institute a Covered Business Method patent review and proceed to cancel claims 1-26 of the ’204 patent as unpatentable for claiming ineligible subject matter under 35 U.S.C. § 101.