PTAB

CBM2016-00053

Apple Inc v. Ameranth Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Information Management and Synchronous Communications System
  • Brief Description: The ’060 patent describes a system for managing information and communications for the hospitality industry. It purports to facilitate database synchronization across wired, wireless, and web-based platforms to computerize activities like food ordering and reservations using handheld devices.

3. Grounds for Unpatentability

Ground 1: Obviousness over DeLorme and Murray - Claims 1-5, 10-13, 15-19, and 21-23 are obvious over DeLorme in view of Murray.

  • Prior Art Relied Upon: DeLorme (Patent 5,948,040) and Murray (Patent 5,944,781).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that DeLorme disclosed all major elements of the challenged claims through its Travel Reservation and Information Planning System (TRIPS). The TRIPS system was described as an information management system for travel planning, accessible via the internet or wireless handheld devices, that provided users with synchronized, real-time travel data from a central relational database. Petitioner contended the only limitation not explicitly taught by DeLorme was a hospitality application stored on both the wireless device and in the master database. This limitation, Petitioner asserted, was taught by Murray, which disclosed a method for distributing Java applet applications from a server-side database to remote clients over the internet.
    • Motivation to Combine: A POSITA would combine DeLorme’s system with Murray’s method of application distribution to solve a known problem. Distributing applications as taught by Murray would be particularly desirable for the wireless devices in DeLorme’s system, as those devices typically had limited storage and disparate architectures. This combination would allow for efficient operation on low-storage devices and facilitate software updates for users.
    • Expectation of Success: Combining Murray’s well-understood applet distribution method with DeLorme’s system would have been a mere design choice with predictable and successful results.

Ground 2: Obviousness over Brandt and NetHopper - Claims 13, 15, 18, 19, and 21 are obvious over Brandt in view of NetHopper.

  • Prior Art Relied Upon: Brandt (Japanese Published Application No. H10-247183) and NetHopper (NetHopper Version 3.2 User’s Manual).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Brandt disclosed a client/server system for providing access to software applications (including a "car rental example") over the web using handheld devices. Brandt’s system included an application gateway, a web server, and a database, which together provided a web-based interface to hospitality applications. Petitioner argued the key missing element was storing the hospitality application (e.g., HTML templates used for car rentals) on both the wireless device and in the master database. This was supplied by NetHopper, a web browser for the Apple Newton PDA, which taught caching web pages and offline form-filling capabilities. This caching functionality meant the application web pages could be stored locally on the device.
    • Motivation to Combine: A POSITA would combine Brandt and NetHopper to improve usability and reliability. Utilizing NetHopper's caching and offline features with Brandt's system would provide crucial support for disconnected clients, allowing a user to fill out a reservation form on a wireless device even during periods of intermittent network connectivity.
    • Expectation of Success: Implementing known web page caching (NetHopper) within a web-based application system (Brandt) was a straightforward technical implementation with a high expectation of success.

  • Additional Grounds: Petitioner asserted numerous other obviousness grounds, including combinations of DeLorme and Murray with Asikainen (for text messaging), Park (for touch-tone recognition), Hettish (for instant messaging/email), Oracle 8.0 Utilities (for database importation), and Carter (for wait-listing). Petitioner also asserted grounds combining Brandt and NetHopper with Oracle, Nokia, Ogram (for payment processing), and Carter. Finally, Petitioner argued that claims 1-12 are unpatentable for indefiniteness under 35 U.S.C. §112 due to the claim term "communications setup," which lacks antecedent basis and sufficient description in the specification.

4. Key Claim Construction Positions

  • "hospitality applications": Petitioner argued for adopting the Board's construction from a related CBM proceeding, defining the term as "applications used to perform services or tasks in the hospitality industry." This construction is broad enough to include businesses that provide services to travelers, such as the travel planning in DeLorme and the car rental agencies in Brandt, making those references applicable to the claims.
  • "communications controller": Petitioner submitted that the broadest reasonable interpretation encompasses the Patent Owner's prosecution history definition: "software code that, when implemented, links all of the claimed computing elements."

5. Relief Requested

  • Petitioner requests institution of a Covered Business Method review and cancellation of claims 1-23 of the ’060 patent as unpatentable.