PTAB

CBM2016-00082

Plaid Technologies Inc. v. Yodlee, Inc.

Title: Method and Apparatus for Restructuring Personalized Data
Brief Description: The ’520 patent describes a system and method for collecting personalized data records from Internet sources, transforming the data from its original format (e.g., HTML) into a new format specific to a non-browser application, and transmitting it to a client's digital appliance (e.g., a PDA or cell phone) for display. The invention purports to address the performance limitations of low-bandwidth and low-memory portable devices.

Core Argument for this Ground: Petitioner argued that all challenged claims are directed to the patent-ineligible abstract idea of transforming data from one format into another, implemented using generic computer components, and thus fail the two-step framework from Alice Corp. v. CLS Bank Int'l.
- Prior Art Mapping: Under Alice step one, Petitioner contended the claims are drawn to the abstract idea of collecting, transforming, and transmitting data. Under Alice step two, Petitioner argued the claims add no inventive concept, instead reciting only generic components (a "server," a "digital appliance") and conventional internet functionality to perform the abstract idea without providing any specific or non-routine technical implementation. Petitioner asserted that independent claims 1 (system) and 21 (method) cover the same abstract idea, and that the dependent claims merely add conventional computer functions or impermissible field-of-use limitations.
- Key Aspects: Petitioner highlighted that a Magistrate Judge in a related district court action had already recommended finding claim 21 invalid under §101 because it was directed to the abstract idea of "transforming data from one form to another" without teaching how the transformation occurs.

Prior Art Relied Upon: MaxMiles Publication (a 1999 publication describing a mileage tracking service), Bull (Patent 5,901,287).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that MaxMiles taught key elements of the claims, including a service that automatically "gathers" client-specific account information from various internet sources and sends a "personalized report" via email. This process inherently involved collecting a record (claim 21(a)), transforming it into a different data form (email for an email reader, not a browser) (claim 21(b)), and transmitting it (claim 21(c)). Bull was argued to supply any missing detail, explicitly teaching an "information aggregation and synthesization" system that retrieves data from the internet ("unformatted from the WWW") and transforms it into various non-browser formats (email, audio, pager messages) for display on devices like PDAs.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Bull's versatile architecture with the MaxMiles service to enhance it by providing users with more display options beyond just email, which was a predictable improvement in the same technological field.
- Expectation of Success: The combination involved applying Bull's known, component-based I/O system to the MaxMiles service, which would have been a routine integration with a high expectation of success.

Prior Art Relied Upon: VerticalOne Publication (a 1999 publication describing a financial aggregation portal), Bull (Patent 5,901,287).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that VerticalOne disclosed a service providing a "single, point-of-access" to financial information from multiple websites, thus teaching the aggregation of client-specific data. Bull again supplied the specific technical implementation, teaching a system that retrieves internet data, transforms it for non-browser applications, and transmits it. Bull’s teaching of a "persistent software text agent" that monitors for new information and provides it to the user directly was argued to disclose the synchronization service of claim 38.
- Motivation to Combine: A POSITA would have been motivated to improve the VerticalOne portal, which required active user login, by incorporating Bull's functionality for passive delivery of information to a user's device (e.g., via email), which is more convenient and allows for offline access.
- Expectation of Success: Combining Bull's known delivery mechanisms with VerticalOne's data aggregation concept was presented as a straightforward modification to improve convenience with a predictable outcome.

Petitioner argued that the invalidity grounds hold true under the Broadest Reasonable Interpretation (BRI) standard and identified two constructions from a parallel district court case that it contended were consistent with BRI.
"transforming the record into a second data form specific to an application other than an Internet browser application...": Petitioner noted the district court construed this term as "designed for an application that is not an Internet browsing application."
"transmitting the transformed record to the digital appliance for display": Petitioner noted the district court construed this term as "outputting for direct or indirect delivery."

A central argument for qualifying the ’520 patent for Covered Business Method (CBM) review was that it is not directed to a "technological invention."
Petitioner contended the patent fails both prongs of the test for a technological invention because (1) the claimed features (e.g., server, digital appliance, aggregation service) were mere recitations of well-known, generic computer technologies, and (2) the patent addresses a non-technical problem (user inconvenience) with a non-technical solution (using generic software to transform data).

Petitioner requested institution of a Covered Business Method review and cancellation of claims 1-40 of the ’520 patent as unpatentable under §101 and §103.