PTAB

CBM2015-00082

Apple Inc v. Ameranth Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Information Management and Synchronous Communications System With Menu Generation
  • Brief Description: The ’325 patent discloses an information management and synchronous communications system for use with wireless handheld devices and the internet. The challenged claims describe a system architecture comprising a central database, a wireless handheld device, a web server, a web page, an application program interface (API), and a communications control module, wherein hospitality applications and data are synchronized across these components.

3. Grounds for Unpatentability

Ground 1: Obviousness over Inkpen, Nokia, Digestor, and Flake

Claims 11-13 and 15 are obvious over Inkpen, Nokia, Digestor, and Flake.

  • Prior Art Relied Upon: Inkpen (a 1998 textbook on travel technology), Nokia (the 1997 owner’s manual for the Nokia 900i Communicator), Digestor (a 1997 article on adapting web content for mobile devices), and Flake (WO 97/27556).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Inkpen disclosed a complete, internet-based hotel reservation system (the Marriott MARSHA system) that met nearly all limitations of the independent claims. Inkpen’s system included a central reservation system and database (MARSHA), a communications switch/interface (THISCO), and a web server (TravelWeb). Nokia disclosed a wireless handheld device with a web browser capable of accessing such a system. Digestor taught methods for automatically re-authoring standard web pages for display on small-screen devices like the one in Nokia. For claim 12, Petitioner asserted Flake disclosed the concept of a waitlist for travel services, a feature commonly used in the hospitality industry.
    • Motivation to Combine: A POSITA would combine Inkpen and Nokia to allow users to access the existing Marriott reservation system from a mobile device, a predictable extension of functionality. Digestor would have been consulted to solve the known problem of adapting web content for smaller screens. A POSITA would incorporate Flake’s waitlist feature into Inkpen’s reservation system to improve its service offerings, a common business practice.
    • Expectation of Success: Combining these elements was a predictable integration of known technologies. Using a web-enabled phone (Nokia) to access a web-based service (Inkpen) using standard internet protocols involved no technical hurdles and would have been expected to work.

Ground 2: Obviousness over DeLorme

Claims 11, 13, and 15 are obvious over DeLorme.

  • Prior Art Relied Upon: DeLorme (Patent 5,948,040).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that DeLorme, as a single reference, disclosed every element of the challenged claims. DeLorme’s Travel Reservation and Information Planning System (TRIPS) was described as an integrated system for planning travel. It included a centralized relational database, access via the internet through a "TRIPS Internet World Wide Web Site," and access via wireless handheld communication units for users "on the go." Petitioner argued DeLorme explicitly taught that users could access updated, synchronized, "real time" travel information regardless of whether they used the web or a wireless device. DeLorme also disclosed an interface for integrating third-party data and a communications bus that functioned as a communications control module.
    • Motivation to Combine: As a single-reference ground, no motivation to combine was necessary. Petitioner argued DeLorme’s system was designed for the very purpose claimed in the ’325 patent: providing synchronized information to both web and mobile users from a central database.

Ground 3: Obviousness over Blinn in view of Inkpen

Claims 11-13 and 15 are obvious over Blinn in view of Inkpen.

  • Prior Art Relied Upon: Blinn (Patent 6,058,373) and Inkpen (a 1998 textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Blinn disclosed a general-purpose system architecture for processing electronic sales transactions that mapped directly onto the claimed system. Blinn’s system included client devices (such as wireless personal digital assistants), the internet, and a merchant system with a database, a web server, and communications controls. Blinn’s architecture was designed to support synchronized online transactions. Inkpen provided the specific context of hospitality applications (hotel reservations).
    • Motivation to Combine: A POSITA would combine the references to implement a hospitality-focused e-commerce system. Blinn provided a known, flexible technical framework for online sales, and a POSITA would have been motivated to apply this framework to the specific, well-known commercial field of hotel and travel reservations as described in Inkpen. This combination represented applying a known technique (Blinn's e-commerce system) to a known field of use (Inkpen's hospitality systems) to yield predictable results.
    • Expectation of Success: Integrating hospitality-specific software into a general e-commerce platform like Blinn's was a straightforward application of known software development principles with a high expectation of success.

4. Key Claim Construction Positions

Petitioner proposed constructions for several key terms, arguing they were critical to the invalidity analysis.

  • "communications control module": Petitioner argued this should be construed as "a device used as an intermediary in transferring communications to and from the host computer to which it is connected." This construction aligns the term with standard components like a communications controller or switch, which Petitioner identified in the prior art (e.g., the THISCO switch in Inkpen).
  • "data are synchronized between [the components]": Petitioner proposed this means "the same data is present in each of the [listed components] at one time." This construction supports the argument that prior art systems which ensure data consistency across a central server and remote clients (via web pages or mobile apps) meet the limitation.

5. Relief Requested

  • Petitioner requests institution of Covered Business Method (CBM) review and cancellation of claims 11-13 and 15 of the ’325 patent as unpatentable.