PTAB

IPR2013-00007

Kyocera Corp v. Softview LLC

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1. Case Identification

2. Patent Overview

  • Title: Scalable Display of Internet Content on Mobile Devices
  • Brief Description: The ’353 patent describes a system and method for translating web content, typically from HTML, into a scalable vector representation. This conversion allows the content to be efficiently rendered, zoomed, and panned on mobile devices with varying display sizes while preserving the original layout.

3. Grounds for Unpatentability

Ground 1: Obviousness over Zaurus and Pad++ - Claims 1, 33, 36, 43, 48, 51, 52, 58, 59, 118, 138, 139, 149, 183, 252, 283, and 317 are obvious over Zaurus in view of Pad++.

  • Prior Art Relied Upon: Zaurus (a series of technical brochures and articles for the Sharp Zaurus PDA) and Pad++ (a collection of technical papers describing a zoomable graphical interface system).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zaurus, a popular PDA from the 1990s, taught the hardware limitations of the challenged claims, including a wireless device with a processor, memory, display, and an internet browser with basic zooming capabilities. Petitioner asserted that Pad++ taught the claimed software methods. Specifically, Pad++ disclosed a zoomable web browser that translated standard HTML content into scalable, "vector-based" objects. This system preserved the original page layout during zooming and panning by associating each page element with an (x,y) coordinate relative to a common datum point (a fixed origin), effectively creating a vector for each object. The dependent claims requiring vector-based content, zooming on images or columns, and parsing HTML into objects with associated data were all allegedly disclosed by the combination.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to improve the rudimentary zooming capabilities of a device like the Zaurus by implementing the more sophisticated and well-documented vector-based zooming techniques of Pad++. The goal was to enhance the user experience of browsing full-featured web pages on a small-screen device, a well-known problem at the time. Applying the known software solution of Pad++ to the known mobile platform of Zaurus was presented as an obvious design choice.
    • Expectation of Success: Petitioner implicitly argued a POSITA would have a high expectation of success, as combining known software for processing web pages with a known hardware device capable of browsing the internet was a predictable and straightforward integration.

Ground 2: Obviousness over Zaurus, Tsutsumitake, and Hara - Claims 1, 33, 36, 43, 48, 51, 52, 58, 59, 118, 138, 139, 149, 183, 252, 283, and 317 are obvious over Zaurus in view of Tsutsumitake and Hara.

  • Prior Art Relied Upon: Zaurus (PDA technical documents), Tsutsumitake (Japanese Application No. H10-21224), and Hara (Japanese Application Publication H10-326169).

  • Core Argument for this Ground:

    • Prior Art Mapping: As in Ground 1, Zaurus was used to teach the base mobile device with a web browser. Petitioner argued that Tsutsumitake and Hara collectively taught the claimed content processing. Tsutsumitake disclosed converting HTML documents into a second, display-friendly format that utilized coordinates relative to a reference point, grouping content into objects, and generating bounding boxes. Hara disclosed a protocol for modifying the display size of image data based on screen resolution. Petitioner asserted Hara taught translating web content into scalable data (defined by height, width, and position relative to a datum) and scaling it to fit a mobile device's display, thus preserving the original layout.
    • Motivation to Combine: The motivation was to solve the known problem of adapting standard web content for small displays. Petitioner argued a POSITA would logically combine the Zaurus mobile platform with the specific HTML-to-vector conversion method of Tsutsumitake and the resolution-aware scaling techniques of Hara. This combination would directly address the need to render complex web pages on a PDA in a usable, scalable format.
    • Expectation of Success: The combination involved applying known data conversion and scaling techniques to a standard mobile device, which Petitioner asserted would have been a predictable endeavor for a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Zaurus, Pad++, Tsutsumitake, and Hara with other references teaching scalable vector graphics, including Scalable Vector Graphics (SVG) Requirements, the Simple Vector Format (SVF) specifications, and Vector Markup Language (VML). These grounds argued that adding SVG, SVF, or VML provided further detail and motivation for using standardized vector-based formats to achieve the claimed scalable rendering on a mobile device.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 33, 36, 43, 48, 51, 52, 58, 59, 66, 118, 138, 139, 149, 183, 252, 283, and 317 of the ’353 patent as unpatentable under 35 U.S.C. §103.