PTAB

CBM2015-00097

Expedia Inc v. Ameranth Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Information Management and Synchronous Communications System with Menu Generation
  • Brief Description: The ’325 patent describes an information management and synchronous communications system for use with wireless handheld computing devices. The challenged claims recite a system architecture comprising a central database, a wireless handheld device, a web server, and a web page, where hospitality applications and data are stored and synchronized across these components.

3. Grounds for Unpatentability

Ground 1: Claims 11, 13, and 15 are obvious over Inkpen in view of Digestor and Nokia.

  • Prior Art Relied Upon: Inkpen (a 1998 book, Information Technology for Travel and Tourism), Digestor (a 1997 technical paper, Device Independent Access to the World Wide Web), and Nokia (a 1997 Nokia 9000i Communicator Owner's Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Inkpen’s description of the Marriott hotel reservation system disclosed the core architectural elements of the claims. Specifically, Inkpen’s MARSHA computerized reservation system and associated database constituted the "central database," its TravelWeb Internet server was the "web server," and its THISCO switch, which managed communications between different systems, functioned as the "communications control module" and provided an "application program interface." Petitioner contended that Nokia disclosed a qualifying "wireless handheld computing device" with a web browser, and Digestor taught methods for automatically re-authoring and reformatting web content for display on such small-screen devices.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Inkpen's reservation system with the handheld device of Nokia to provide mobile access, a well-known goal at the time. A POSITA would have been further motivated to incorporate the teachings of Digestor to solve the known and predictable problem of formatting web content from a server (like Inkpen's) for optimal viewing on a small-screen device (like Nokia's).
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination merely applied known web-adaptation techniques to enable a known type of device to access a known type of online service.

Ground 2: 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 asserted that the DeLorme patent, as a single reference, disclosed every element of the challenged claims. DeLorme’s Travel Reservation and Information Planning System (TRIPS) was described as a "completely integrated system" accessible both online via a "TRIPS Internet World Wide Web Site" and by mobile users via a "wireless communication unit" (WCU), such as a handheld device. Petitioner mapped DeLorme’s "state-of-the-art relational database" to the "central database," its WCU to the "wireless handheld device," its TRIPS website to the "web server" and "web page," its Provider Input/Output functionality to the "application program interface," and its "Interface & Interaction Bus" to the "communications control module." DeLorme explicitly taught that data was synchronized to provide "real-time" and "on the spot" information to both online and mobile users.

Ground 3: 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 book).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Blinn disclosed a complete, generic architecture for electronic merchandising that met the structural limitations of the claims. Blinn’s system included a "merchant system" with one or more databases ("central database"), an "Internet information server" ("web server"), and client devices including "interactive wireless communications device[s]" like PDAs ("wireless handheld computing device"). Blinn’s system also used a router and TCP/IP stack that functioned as a "communications control module." While Blinn’s system was generic, it was designed to be customized for a "merchant's unique sales transactions."
    • Motivation to Combine: A POSITA would combine the generic e-commerce framework of Blinn with the specific "hospitality applications" disclosed in Inkpen. Petitioner argued this combination represented a predictable use of a known technology (Blinn's adaptable sales platform) for a known application (Inkpen's hotel reservation services) to achieve a predictable result. This integration was merely an obvious design choice to apply a known business practice to an existing technical framework.
    • Expectation of Success: A POSITA would have reasonably expected success in implementing Inkpen's hospitality logic on Blinn's flexible e-commerce architecture, as Blinn was explicitly designed to be adapted for various types of sales transactions.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 12, adding Flake (WO 97/27556) to the Inkpen/Nokia/Digestor combination to teach the claimed limitation of synchronized data related to waitlists.

4. Key Claim Construction Positions

  • "web page": Petitioner adopted the Board's prior construction from a related matter: "a document, with associated files for graphics, scripts, and other resources, accessible over the internet and viewable in a web browser."
  • "communications control module": Petitioner proposed the construction "a device used as an intermediary in transferring communications to and from the host computer to which it is connected," relying on a technical dictionary definition for "communications controller."
  • "data are synchronized...": Petitioner proposed construing this phrase to mean "the same data is present in each of the central database, the at least one wireless handheld computing device, at least one Web server and at least one Web page at one time." This position was based on statements made by the Patent Owner in related litigation.

5. Relief Requested

  • Petitioner requested institution of a Covered Business Method review and cancellation of claims 11-13 and 15 of Patent 6,871,325 as unpatentable.