Starbucks Corp v. Ameranth Inc

1. Case Identification

• Case #: CBM2015-00091
• Patent #: 6,384,850
• Filed: March 2, 2015
• Petitioner(s): Starbucks Corporation
• Patent Owner(s): Ameranth, Inc.
• Challenged Claims: 12-16

2. Patent Overview

• Title: Information Management and Synchronous Communications System and Method
• Brief Description: The ’850 patent describes a system for computerizing hospitality industry activities, such as ordering food and making reservations, using wireless handheld devices and the internet. The claimed invention is directed to an information management system that synchronizes applications and data between a central database, a web server, a web page, and multiple wireless handheld devices.

3. Grounds for Unpatentability

Ground 1: Claims 12-16 are obvious over Brandt in view of NetHopper.

• Prior Art Relied Upon: Brandt (Japanese Application # H10-247183) and NetHopper (NetHopper Version 3.2 User’s Manual).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Brandt, an IBM application, disclosed a complete client-server system for providing web-based access to software applications, including a "car rental" hospitality application, from handheld devices like PDAs. Brandt’s system used a central "application gateway" (the claimed "communications control module") to manage communication and data flow between client web browsers and a central database, thereby synchronizing data. Petitioner asserted that NetHopper, a web browser for the Apple Newton PDA, taught caching web pages and offline form data. The combination of Brandt’s system with NetHopper’s known functionality would result in the storage of hospitality application data on the wireless device as claimed.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Brandt’s web-based application system with a known handheld web browser like NetHopper to enable access from mobile devices. Furthermore, NetHopper’s caching and offline form-filling capabilities would have been an obvious and advantageous feature to add to Brandt's system to provide support for disconnected clients, allowing users to complete tasks like a car rental reservation even with an intermittent wireless connection.
  • Expectation of Success: Combining a known web application architecture with a compatible client-side web browser that offered caching was a routine and predictable task for a POSITA at the time.

Ground 2: Claims 12-16 are obvious over Brandt in view of Demers and Alonso.

• Prior Art Relied Upon: Brandt (Japanese Application # H10-247183), Demers (a 1994 conference paper on the Bayou Architecture), and Alonso (a 1996 paper on workflow management for mobile clients).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground again relied on Brandt for the foundational client-server architecture. However, to teach a more robust system for offline operation and data synchronization, Petitioner cited Demers and Alonso. Alonso specifically taught adding disconnected client support to the same IBM FlowMark workflow system disclosed in Brandt by having the mobile computer download necessary data to work offline and then synchronize updates upon reconnection. Demers taught the well-known Bayou system, which provided a specific technical approach for implementing such functionality using replicated mobile databases that synchronize with a primary server-side database. This combination taught the storage and synchronization of hospitality application data on a handheld device.
  • Motivation to Combine: A POSITA seeking to improve the accessibility and utility of Brandt's FlowMark-based system would have been motivated by Alonso to add disconnected client support for mobile users. To implement this functionality, the POSITA would have naturally looked to well-known and established mobile database replication systems like the Bayou system described in Demers.
  • Expectation of Success: The references collectively provided a clear technical roadmap for implementing robust offline capabilities in Brandt's system, and a POSITA would have had a reasonable expectation of success in doing so.

• Additional Grounds: Petitioner asserted additional challenges under 35 U.S.C. §112 and §101. The multiple §112 grounds argued that the patent’s specification failed to enable key limitations, such as the "communications control module" and the method of storing and synchronizing entire "applications and data" across four distinct locations. The §101 ground argued the claims were directed to the patent-ineligible abstract idea of computerizing routine and long-standing hospitality activities.

4. Key Technical Contentions (Beyond Claim Construction)

• "Hospitality Applications and Data" Synchronization: Petitioner contended that the patent failed to provide an enabling disclosure for how "hospitality applications and data" could be stored across and synchronized between the four distinct recited locations (a central database, a handheld device, a web server, and a web page). It was argued that the concept of storing an entire application on a web page or synchronizing applications themselves (as opposed to just data) was technically ambiguous, unsupported by the specification, and would require undue experimentation to implement.
• "Communications Control Module": Petitioner argued that the specification provided conflicting characterizations of the "communications control module," describing it both as a centralized system component (running on a desktop PC) and as a distributed software abstraction layer that interfaces with applications on each device. Petitioner contended this contradiction, along with a lack of any meaningful implementation details, rendered the claims fatally indefinite and non-enabled.

5. Relief Requested

• Petitioner requests institution of a Covered Business Method patent review and cancellation of claims 12-16 of the ’850 patent as unpatentable.