PTAB

CBM2016-00082

Plaid Technologies Inc v. Yodlee Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method And Apparatus For Restructuring Of Personalized Data For Transmission From A Data Network To Connected And Portable Network Appliances
  • Brief Description: The ’520 patent discloses a system for collecting personalized data (e.g., bank statements, travel reservations) for a user from various internet sources. The system transforms the data from its original internet format into a second format specific to a non-browser application on a user's digital device (e.g., a PDA or mobile phone) and transmits the transformed data to that device for display.

3. Grounds for Unpatentability

Ground 1: Patent Ineligibility under 35 U.S.C. § 101 - Claims 1-40 are directed to an abstract idea.

  • 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 to another and are unpatentable under the two-step framework from Alice Corp. v. CLS Bank Int'l.
    • Alice Step 1: The claims were argued to be directed to the abstract concept of collecting data, transforming its format, and displaying it. Petitioner contended this is a longstanding, fundamental practice analogous to gathering data and creating a summary, merely performed using the Internet. The claims do not limit the method of transformation but recite the abstract result in broad, functional language.
    • Alice Step 2: Petitioner asserted the claims lack an inventive concept, as they merely instruct performing the abstract idea using generic, conventional computer components. The claims recite a generic "server," "digital appliance," and "software" without specifying any novel structure or functionality beyond their basic, well-understood roles. Petitioner argued that dependent claims add only conventional computer-related limitations (e.g., CRC checks), conventional method steps (e.g., generating alarms), or field-of-use limitations (e.g., billing schedules), none of which transform the abstract idea into a patent-eligible application.

Ground 2: Obviousness over MaxMiles and Bull - Claims 21, 37, and 38 are obvious over MaxMiles Publication in view of Bull.

  • Prior Art Relied Upon: MaxMiles Publication ("Take your Miles to the Max with MaxMiles MileageMiner") and Bull (Patent 5,901,287).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued MaxMiles, a frequent flyer mileage tracking service, taught collecting personalized account information for a specific client from internet sources (airlines, hotels) and sending a "personalized report" via email. This taught the core concept of collecting, aggregating (claim 37), and transmitting user-specific records. Bull disclosed a system for retrieving information from the internet and delivering it in various non-browser formats (email, audio, pager messages) to devices like PDAs. Bull provided the missing technical details for transforming data from an internet format to a format specific to a non-browser application and transmitting it to a user's device.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references because they address the same technological field: retrieving and presenting user-specific, travel-related information. A POSITA would have been motivated to enhance the MaxMiles service by incorporating Bull’s more versatile system for delivering information in multiple formats beyond just email, allowing users to receive updates on various devices as taught by Bull.
    • Expectation of Success: The combination involved applying the known output and formatting capabilities of Bull's system to the data aggregation service of MaxMiles. This integration of known components to achieve a predictable result would have presented no technical difficulties and carried a high expectation of success.

Ground 3: Obviousness over VerticalOne and Bull - Claims 21, 37, and 38 are obvious over VerticalOne Publication in view of Bull.

  • Prior Art Relied Upon: VerticalOne Publication ("VerticalOne Corporation to Offer Internet Users One-stop for Managing Online Personal Content and Account Information") and Bull (Patent 5,901,287).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that VerticalOne taught a portal providing a "single, point-of-access" to a user's personal financial information (bank statements, credit card balances) from various websites. This disclosed a service for retrieving and aggregating (claim 37) client-specific records from internet sources. While VerticalOne provided a "snapshot" of current data, it required a user to actively log into a portal. Bull taught a system for transforming internet data into non-browser formats and delivering it to user devices, including via a persistent agent that could provide updates automatically (claim 38).
    • Motivation to Combine: A POSITA would be motivated to improve the user experience of the VerticalOne portal. The portal required an active user login and internet connection to view information. By incorporating Bull's teachings, a POSITA could enhance VerticalOne to passively push updates to users in various formats (e.g., email, pager alerts), allowing for more convenient access to financial information without needing to log in, including offline access after delivery.
    • Expectation of Success: The combination represented the routine application of Bull's component-based I/O system to the VerticalOne data aggregation service. Implementing a known method of data delivery (Bull) to a known type of aggregated data (VerticalOne) was a predictable modification with a reasonable expectation of success.

4. Key Claim Construction Positions

  • “transforming the record into a second data form specific to an application other than an Internet browser application...” (claim 21): Petitioner proposed construing the phrase “form specific to an application other than an Internet browser application” as “designed for an application that is not an Internet browsing application,” consistent with a construction from a related district court action.
  • “transmitting the transformed record to the digital appliance for display” (claim 21): Petitioner proposed construing this phrase as “outputting for direct or indirect delivery,” also consistent with the related district court action.

5. Relief Requested

  • Petitioner requested institution of a Covered Business Method review and cancellation of claims 1-40 of the ’520 patent as unpatentable under 35 U.S.C. § 101, and cancellation of claims 21, 37, and 38 as unpatentable under 35 U.S.C. § 103.