PTAB

IPR2014-00200

Yahoo Inc v. CReaTeads LLC

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1. Case Identification

2. Patent Overview

  • Title: Method of Generating a Visual Design
  • Brief Description: The ’320 patent relates to a method for generating visual designs for various applications. The method involves storing data for visual elements and design parameters, selecting an application and elements, and automatically generating a design where the size and position of elements are determined by the parameters associated with the selected application.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-20 by Sieber and Sieber PCT

  • Prior Art Relied Upon: Sieber (Patent 5,649,216) and Sieber PCT (WO 92/21097).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sieber and Sieber PCT each disclose a method for automatically generating a page layout for documents like business cards and greeting cards from user-defined text and graphic elements. The references teach storing a plurality of "page specifications" (the claimed "visual design applications"), each comprising "constraints" (the claimed "predetermined design parameters") that define the layout. A user selects a page specification and enters information, and the system generates a layout by positioning the elements according to the stored constraints, thereby satisfying the limitations of independent claims 1 and 14. Petitioner asserted that Sieber and Sieber PCT also disclose every limitation of the dependent claims, such as including text elements (claim 2), using parameters for viewing distance and spacing (claim 3), and generating a display (claim 11).

Ground 2: Anticipation of Claims 1-20 by Amari

  • Prior Art Relied Upon: Amari (a 1987 publication titled Automating the Design of Packaging Families Using PackIT).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Amari discloses a design system (PackIT) for creating layouts for product packaging. The system stores graphic objects ("visual design elements") and a knowledge base of graphic design rules ("predetermined design parameters"). A user selects a package type ("visual design application") and graphic objects, and the system uses its rule base to automatically lay out the objects on a computer display, creating a design consistent with the product family. Petitioner argued this process meets all limitations of independent claims 1 and 14, as the rules determine the size, position, and relation of elements based on the selected package type. Amari was also argued to inherently disclose dependent claim limitations, such as using rules for different intended viewing distances for various products (e.g., packages, business cards, vehicle graphics) to maintain visual unity.

Ground 3: Obviousness of Claims 3, 5, 16, and 18 over Sieber/Sieber PCT in view of Feiner

  • Prior Art Relied Upon: Sieber (Patent 5,649,216) or Sieber PCT (WO 92/21097), in view of Feiner (a 1988 publication titled A Grid-Based Approach to Automating Display Layout).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that to the extent Sieber or Sieber PCT are found not to explicitly disclose using an "intended viewing distance" as a design parameter, the addition of this feature would have been obvious. Sieber teaches generating aesthetically pleasing layouts for various documents (e.g., business cards, advertisements) which are intended to be viewed from different distances. Feiner explicitly teaches using the intended viewing distance of a display, in conjunction with legibility rules, to determine the appropriate size and layout of text and pictures.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the automated layout system of Sieber with the well-known design principles taught by Feiner to ensure that the generated designs were legible and effective for their intended purpose. A POSITA would have naturally considered viewing distance when setting the design constraints in Sieber’s system to create a functional and aesthetically pleasing document.
    • Expectation of Success: The combination was a simple application of conventional design principles to an existing automated system. A POSITA would have had a high expectation of success because incorporating rules for legibility based on viewing distance was a routine and predictable design consideration.

  • Additional Grounds: Petitioner asserted additional anticipation challenges against various claims based on Powell (Patent 4,873,643). Petitioner also asserted obviousness challenges for claims 6 and 9 over Sieber/Sieber PCT, either alone or in combination with Amari and/or Powell, arguing that the inclusion of predetermined text or specific applications like stationery and packaging was an obvious modification.

4. Key Claim Construction Positions

  • "Predetermined design parameters": Petitioner proposed this term means "predetermined parameters that affect the appearance of the visual design," including examples such as intended viewing distance, relative spacing, sizing, and positioning. This construction was central to arguing that the "constraints" in Sieber and the "rules" in Amari met this limitation.
  • "Predetermined visual design applications": Petitioner proposed this term means "predetermined applications of the visual design," including examples like stationery, signage, packaging, and advertisements. This broad construction allowed Petitioner to map the term to the "page specifications" of Sieber and the different package types of Amari.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of the ’320 patent as unpatentable.