PTAB

IPR2013-00256

Motorola Mobility LLC v. Softview LLC

Key Events

Petition

petition Intelligence

Case #: IPR2013-00256
Patent #: 7,461,353
Filed: April 29, 2013
Petitioner(s): Motorola Mobility LLC
Patent Owner(s): SoftView LLC
Challenged Claims: 1, 33, 36, 43, 48, 51, 52, 58, 59, 66, 118, 138, 139, 149, 183, 252, 283, and 317

Title: Scalable Display of Internet Content on Mobile Devices
Brief Description: The ’353 patent discloses systems and methods for translating web content from a native format like HTML into a "scalable vector representation." This conversion allows the content to be efficiently scaled, zoomed, and panned on mobile devices with varying screen sizes while preserving the original page layout.

Prior Art Relied Upon: Zaurus (materials related to the Sharp Zaurus PDA, Exhibit PX1004) and Pad++ (publications related to the Pad++ zoomable interface system, Exhibit PX1006).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued Zaurus, a commercially available Personal Digital Assistant (PDA) from the 1990s, taught the claimed hardware elements (processor, display, memory, wireless communications) and a functional web browser with basic zoom capabilities. Pad++ taught a zoomable graphical interface system that translated standard HTML into scalable, vector-based objects. Pad++ disclosed defining objects relative to a primary datum (origin), generating vectors for object placement, and preserving layout during zooming, thereby teaching the core processing limitations of the challenged claims.
- Motivation to Combine: A POSITA would combine the advanced vector-based zooming and layout preservation techniques of Pad++ with the established mobile browsing platform of Zaurus. The motivation was to solve the well-known problem of navigating and viewing complex web pages on the small, low-resolution screens of PDAs like Zaurus.
- Expectation of Success: A POSITA would have a reasonable expectation of success because applying known graphical interface techniques (from Pad++) to improve the user experience of existing software (Zaurus's browser) was a predictable and straightforward path of innovation at the time.

Prior Art Relied Upon: Zaurus (Exhibit PX1004), Tsutsumitake (Japanese Application No. H10-21224), and Hara (Japanese Application Publication H10-326169).
Core Argument for this Ground:
- Prior Art Mapping: This ground presented an alternative combination where Zaurus again supplied the base mobile device platform. Tsutsumitake taught converting HTML documents into a second format using coordinates relative to a reference point and grouping content into objects with bounding boxes. Hara taught a protocol for modifying the display size of image data based on screen resolution and disclosed translating web content into position data relative to a fixed datum point for scaling.
- Motivation to Combine: The motivation was to improve the functionality of the Zaurus web browser for small displays. Tsutsumitake and Hara collectively provided a detailed methodology for converting HTML into a scalable format suitable for different screen resolutions, which directly addressed the core problem the ’353 patent purports to solve, making their combination with a device like Zaurus obvious.

Prior Art Relied Upon: Zaurus (Exhibit PX1004), Pad++ (Exhibit PX1006), and SVG (W3C Scalable Vector Graphics Requirements, Exhibit PX1007).
Core Argument for this Ground:
- Prior Art Mapping: This ground specifically targeted claim 66, which recites that HTML-based web content comprises "cascaded style sheet [CSS] data" that is preserved at each zoom level. Petitioner asserted that Zaurus in view of Pad++ taught the base mobile device and scalable rendering system. The SVG reference, a W3C standard for vector graphics, explicitly taught the use of CSS to control the styling (e.g., fonts, colors) of vector content, ensuring that these design aspects are honored by conforming processors.
- Motivation to Combine: One stated goal of the SVG standard was its use on devices with a wide range of resolutions, from small mobile devices to large displays. A POSITA, having already been motivated to create a vector-based browser by combining Zaurus and Pad++, would naturally look to the emerging SVG standard and its integrated CSS support to manage the styling of web content in a scalable and consistent manner.

For the purposes of the IPR, Petitioner accepted the Patent Owner's proposed constructions as consistent with the broadest reasonable interpretation standard. Key accepted constructions included:
- scalable content: "graphic content capable of being rendered at multiple zoom levels"
- vector-based content: "graphic content that includes one or more vectors"
- processing [the] HTML-based Web content to produce scalable content: "processing [the] HTML-based Web content to produce content capable of being zoomed in or out"

Petitioner filed a concurrent motion for joinder with an already-instituted IPR, IPR2013-00007 ("Kyocera IPR"), filed by Kyocera Corporation against the same ’353 patent. Petitioner argued that joinder would promote efficiency and consistency, as the asserted grounds and prior art largely corresponded to those already under review in the Kyocera IPR.

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.