PTAB

IPR2013-00257

Motorola Mobility LLC 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 ’926 patent discloses a system and method for translating web content, typically from HTML, into a scalable vector representation. This process is intended to simplify zooming, panning, and scaling of web pages for optimal display across devices with different screen sizes and resolutions, from mobile phones to large monitors.

3. Grounds for Unpatentability

Ground 1: Obviousness over Zaurus, Pad++, and SVF - Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious over Zaurus in view of Pad++ and the SVF References.

  • Prior Art Relied Upon: Zaurus (a series of Sharp PDAs with web browsers, Exhibit PX1004), Pad++ (a zoomable graphical interface system, Exhibit PX1006), and SVF References (Specification for the Simple Vector Format v 1.1, Exhibit PX1009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zaurus, a commercially available PDA from the early 1990s, taught the core mobile device with a processor, display, memory, and a web browser capable of rendering HTML and performing zoom functions. Pad++, a graphical interface system, taught translating standard HTML into scalable, vector-based objects. It disclosed generating vectors for objects from a primary datum to an object datum, enabling zooming and panning while preserving layout. The SVF References further taught a simple, vector-based format for web content that used a base coordinate system (0,0), described vectors by their endpoints, and supported zooming, panning, and hyperlinks via browser plug-ins.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve the known challenge of viewing web pages on small-screen devices. Zaurus provided the mobile platform with a basic browser, while Pad++ and the SVF References provided known methods for translating web content into a vector format to enable superior scaling and zooming. Petitioner asserted that applying these known vectorization techniques to the Zaurus platform was a predictable solution to enhance its web browsing functionality.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the references taught implementing vector graphics via straightforward techniques like browser plug-ins (SVF) and described the underlying coordinate systems and object handling (Pad++), making the integration with a standard browser like Zaurus’s predictable.

Ground 2: Obviousness over Zaurus, Hara, Tsutsumitake, and SVG - Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious over Zaurus in view of Hara, Tsutsumitake, and SVG.

  • Prior Art Relied Upon: Zaurus (Exhibit PX1004), Hara (Japanese Application Publication H10-326169), Tsutsumitake (Japanese Application No. H10-21224), and SVG (W3C Scalable Vector Graphics Requirements, Exhibit PX1007).

  • Core Argument for this Ground:

    • Prior Art Mapping: As in the first ground, Petitioner contended Zaurus provided the foundational mobile device and browser. Hara taught a protocol for modifying the display size of image data according to screen resolution, including translating web content into height, width, and position data relative to a fixed datum. Tsutsumitake similarly taught converting HTML into a second format suitable for screen display that uses coordinates relative to a reference point, grouping content into objects, and generating bounding boxes. Finally, SVG, a well-known W3C standard, taught scalable vector-based content for the web, explicitly including zooming, panning, and HTML functionality.
    • Motivation to Combine: A POSITA would combine these references to solve the problem of fitting content designed for large monitors onto the small screen of a mobile device like Zaurus. Hara and Tsutsumitake provided specific methods for translating and scaling web content based on display resolution. A POSITA would naturally look to these techniques and the industry-standard SVG framework to improve the rendering capabilities of Zaurus’s web browser, making web pages more usable on the go.
    • Expectation of Success: The combination was a simple application of known scaling techniques to an existing device. Hara and Tsutsumitake provided detailed teachings on converting HTML to scalable formats, and SVG was an open standard developed specifically for this purpose, ensuring a high likelihood of successful implementation.

  • Additional Grounds: Petitioner noted that other combinations of prior art submitted by Kyocera Corporation in a related inter partes review (IPR) were found by the PTAB to be redundant or cumulative and were therefore intentionally omitted from this petition.

4. Key Claim Construction Positions

  • For the purposes of this IPR, Petitioner stated it would adopt the claim constructions proposed by the Patent Owner, SoftView LLC, in the related district court litigation. Petitioner submitted these constructions as being consistent with the broadest reasonable interpretation standard.
  • "scalable content": "graphic content capable of being rendered at multiple zoom levels"
  • "scalable vector-based content": "graphic content that (1) is capable of being rendered at multiple zoom levels and (2) includes one or more vectors"
  • "vector": "A mathematical expression representing a length and a direction in a two dimensional space..."

5. Relief Requested

  • Petitioner requested the institution of an IPR and the cancellation of claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 of the ’926 patent as unpatentable. Petitioner also filed a concurrent request for joinder with the already-instituted IPR2013-00004.