PTAB

CBM2015-00096

Expedia Inc v. Ameranth Inc

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1. Case Identification

2. Patent Overview

  • Title: Information Management and Synchronous Communications System with Menu Generation
  • Brief Description: The ’850 patent relates to an information management and synchronous communications system. While the specification focuses on menu generation (covered by un-challenged claims), challenged claims 12-16 are directed to a system using a central database, wireless handheld device, web server, and web page to synchronize "hospitality applications and data."

3. Grounds for Unpatentability

Ground 1: Obviousness over Travel and Mobile Device References - Claims 12-16 are obvious over Inkpen in view of Nokia and Digestor.

  • Prior Art Relied Upon: Inkpen (a 1998 book on travel information systems), Nokia (a 1997 owner's manual for the Nokia 9000i Communicator), and Digestor (a 1997 paper on adapting web content for small-screen devices).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the prior art discloses all elements of the claimed system. Inkpen’s description of the Marriott hotel reservation system teaches a central database (MARSHA CRS and Marriott database), a communications control module (the THISCO switch), a web server (Travel Web server), and web pages for making reservations. Nokia discloses a commercially available wireless handheld device (the Nokia 9000i) with a web browser. Digestor teaches methods for automatically re-authoring standard web documents for proper display on small-screen devices like the Nokia communicator.
    • Motivation to Combine: A POSITA would combine these references to provide the convenience of mobile access to a known web-based reservation system. It would have been obvious to use a known wireless handheld device (Nokia) to access the known travel reservation system (Inkpen) and to apply the known techniques from Digestor to solve the predictable problem of formatting web pages for the device’s smaller screen.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining a web-enabled handheld device with a web-based service was a common goal, and techniques for reformatting content for such devices were well-established.

Ground 2: Obviousness over DeLorme Travel Planning System - Claims 12-16 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, discloses every limitation of the challenged claims. DeLorme’s Travel Reservation and Information Planning System (TRIPS) is an integrated system for planning travel that includes a central relational database for hospitality data, a web server providing a TRIPS website, and functionality for users to access the system "on the go" using wireless handheld communication units. DeLorme explicitly teaches that users can access updated, "real time" (i.e., synchronized) information whether accessing the system online or via a wireless device.
    • Motivation to Combine: As this ground is based on a single reference, Petitioner argued the motivation is inherent. DeLorme taught a complete, integrated system containing all the claimed elements working together to achieve the same purpose of providing synchronized hospitality information across different platforms, including wireless handheld devices.

Ground 3: Obviousness over E-Commerce System and Hospitality Data - Claims 12-16 are obvious over Blinn in view of Inkpen.

  • Prior Art Relied Upon: Blinn (Patent 6,058,373) and Inkpen (a 1998 book on travel information systems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Blinn discloses a complete, general-purpose architecture for electronic sales transactions. This architecture includes all the structural elements of the claimed system: client devices (including wireless personal digital assistants), a communications medium (the Internet), and a merchant system with a central database, a communications control module, and a web server. Petitioner argued that Blinn’s system was designed to be adapted for different sales situations. Inkpen supplies the specific "hospitality applications and data" that were known in the art.
    • Motivation to Combine: A POSITA would combine Blinn’s e-commerce framework with Inkpen’s hospitality content to create a system for online hospitality transactions. This combination represented the application of a known technology (Blinn's general e-commerce system) to a known application (Inkpen's hospitality field) to achieve predictable results and improve Blinn’s system by enabling a specific, commercially significant type of transaction.

4. Key Claim Construction Positions

  • "communications control module" (claim 12): Petitioner proposed this term be construed to mean "a device used as an intermediary in transferring communications to and from the host computer to which it is connected." This construction is based on the definition of a "communications controller" and aligns with the module's described function of routing messages.
  • "data are synchronized between the central database, the at least one wireless handheld computing device, at least one Web server and at least one Web page" (claim 12): Petitioner proposed this phrase be construed to mean "the same data is present in each of the [listed components] at one time." This position was supported by citing the Patent Owner's own infringement contentions and arguments in a related case, where downloading a menu from one device to another was asserted to constitute synchronization.

5. Relief Requested

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