PTAB

CBM2015-00099

Starbucks Corp v. Ameranth Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Information Management and Synchronous Communications System
  • Brief Description: The ’325 patent relates to an information management and synchronous communications system that facilitates computerizing hospitality-related activities, such as ordering and reservations, using wireless handheld devices in communication with web-based systems.

3. Grounds for Unpatentability

Ground 1: Obviousness Over Brandt, NetHopper, Carter, and Rossmann - Claims 11-13 and 15 are obvious over Brandt in view of NetHopper, Carter, and Rossmann.

  • Prior Art Relied Upon: Brandt (Japanese Application No. H10-247183), NetHopper (NetHopper Version 3.2 User’s Manual), Carter (European Application No. EP 0845748 A2), and Rossmann (Patent 5,809,415).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Brandt taught the core system architecture: a client/server system enabling handheld devices (PDAs) to access software applications (such as a car rental application, a hospitality service) over the internet via a centralized "application gateway." This gateway manages communications, processes user input, and generates dynamic web pages from application data. NetHopper, a web browser for Apple Newton PDAs, disclosed caching web pages and HTML forms, allowing a user to complete forms while disconnected. Carter, another IBM application, disclosed similar internet-based e-commerce, including rental car reservations and waitlists. Finally, Rossmann taught adapting applications for resource-limited devices like pagers that may not run a full web browser. Together, these references disclosed all elements of the challenged claims, including the central database, handheld device, web server, and web page, all storing and synchronizing hospitality application data.
    • Motivation to Combine: A POSITA would combine Brandt's web-accessible application system with NetHopper's PDA browser and caching features to provide support for disconnected clients, a known industry desire. A POSITA would further incorporate the teachings of Carter, another IBM application in the same technical field, to add common e-commerce functionalities like waitlists to Brandt's system. Finally, to broaden device compatibility, a POSITA would integrate Rossmann’s techniques to make the application accessible to simpler, non-browser devices like pagers, a logical extension for a system designed for mobile hospitality use.
    • Expectation of Success: The combination involved integrating known technologies (web servers, handhelds with browsers, data caching) to solve the predictable problem of extending application access to mobile users, including those with intermittent connectivity.

Ground 2: Obviousness Over Brandt, Demers, Alonso, Carter, and Rossmann - Claims 11-13 and 15 are obvious over Brandt in view of Demers, Alonso, Carter, and Rossmann.

  • Prior Art Relied Upon: Brandt (Japanese Application No. H10-247183), Demers (a 1994 conference paper on the Bayou Architecture), Alonso (a 1996 paper on the Exotica/FMDC system), Carter (European Application No. EP 0845748 A2), and Rossmann (Patent 5,809,415).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground relied on the same base system from Brandt but introduced a different, more robust solution for disconnected operation. Alonso specifically taught adding disconnected client support to IBM's FlowMark system—the same workflow management system described in Brandt. Alonso proposed that a mobile computer could download necessary data, work offline, and synchronize updates upon reconnection. Demers provided a well-known technical implementation for such a system, describing the Bayou architecture for replicating and synchronizing mobile databases to allow applications to function during network disconnection. The combination of Brandt, Alonso, and Demers taught storing and synchronizing hospitality data between a central database and a local, replicated database on a wireless handheld device.
    • Motivation to Combine: A POSITA seeking to improve the Brandt system would have been motivated by Alonso, which explicitly addressed adding disconnected support to Brandt's core FlowMark platform. To implement Alonso's suggestion, the POSITA would naturally have looked to well-known solutions for mobile data replication, such as the Bayou system taught by Demers. This combination directly addresses the goal of enabling mobile workflow applications to function offline, a key problem in the field.
    • Expectation of Success: A POSITA would have had a high expectation of success, as Alonso and Brandt addressed the exact same commercial system (FlowMark), and Demers provided a known, practical architecture for implementing the data synchronization required for disconnected operation.

  • Additional Grounds: Petitioner asserted numerous additional grounds of unpatentability. Grounds 1-8 alleged that claims 11-13 and 15 are invalid under pre-AIA 35 U.S.C. §112 for lack of enablement, lack of written description, and indefiniteness. These challenges focused on the specification's failure to describe how to implement key claimed features, such as the "communications control module," the purported "software libraries," and the method for storing and synchronizing "hospitality applications and data" across four distinct locations (database, handheld, web server, web page). Ground 13 argued the claims are invalid under 35 U.S.C. §101 as being directed to the abstract ideas of ordering, making reservations, and managing waitlists, implemented using only generic computer components.

4. Relief Requested

  • Petitioner requested institution of a Covered Business Method patent review and cancellation of claims 11-13 and 15 of the ’325 patent as unpatentable.