PTAB

IPR2014-01474

Veeva Systems Inc v. Prolifiq Software Inc

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1. Case Identification

2. Patent Overview

  • Title: Adaptive Media Messaging, Such as For Rich Media Messages Incorporating Digital Content
  • Brief Description: The ’077 patent discloses systems and methods for adapting electronic messages based on the content-rendering capabilities of a recipient's device. The invention involves transmitting a first version of a message, using logic to detect the receiving device's capabilities, and then displaying a second, adapted version of the message based on the results of the detection.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Walters in view of McMillan

  • Prior Art Relied Upon: Walters (Application # 2001/0052019) and McMillan (Patent 6,789,108).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Walters discloses the core functionality of the ’077 patent by teaching an email system that delivers rich media content in a two-step process. In Walters, a recipient first receives an email with an icon (a first version of the message). Upon clicking the icon, a video is streamed and displayed in a video window (a second version). Petitioner contended that McMillan addresses the known problem of content incompatibility across different recipient devices by teaching a system that detects a device’s operational capabilities (e.g., bandwidth, browser, graphics) and selectively provides compatible content. The combination of Walters’s two-version display method with McMillan’s capability-sensing logic was alleged to render the independent claims (1, 9, 17) obvious.
    • Motivation to Combine: Petitioner asserted a POSITA would combine McMillan with Walters to solve a recognized drawback in Walters’s system, which required the receiving computer to possess the necessary capabilities to display standard multimedia files. By integrating McMillan’s capability detection, the combined system would ensure that the video content delivered by Walters is viewable by all recipients, regardless of their device differences, thus improving the system's overall effectiveness and reliability.
    • Expectation of Success: Petitioner argued that the combination would have been straightforward, as McMillan’s logic for detecting capabilities could be implemented in various ways within Walters’s architecture, such as by embedding it in the initial email or triggering it upon the user clicking the link, without disrupting the overall system.

Ground 2: Claims 1-20 are obvious over Irlam in view of McMillan

  • Prior Art Relied Upon: Irlam (Patent 6,650,890) and McMillan (Patent 6,789,108).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Irlam, like the ’077 patent, addresses the challenges of sending large, rich media files. Irlam discloses transmitting an email with a "replacement attachment" or "thumbnail" version of the media item (the first version). A user can then click a link on the thumbnail to receive the full, high-resolution attachment (the second version). This approach conserves bandwidth. Petitioner asserted that combining Irlam’s thumbnail-based, two-version delivery system with McMillan’s capability-sensing technology meets all limitations of the independent claims. The capability test from McMillan would be initiated upon display of the first version (the thumbnail), and the second version (the full attachment) would be selected and delivered in a format compatible with the recipient's device.
    • Motivation to Combine: A POSITA would have been motivated to combine the teachings to improve Irlam's system. While Irlam addresses bandwidth issues, it does not solve the problem of media format incompatibility across different devices. By incorporating McMillan’s capability detection, the system would ensure that the full version of the content downloaded by the user is actually viewable on their specific device, thereby making Irlam’s system more robust and functional.
    • Expectation of Success: Petitioner contended the combination was predictable, as the logic for capability detection from McMillan could be easily integrated with the initial message containing the thumbnail taught by Irlam. This would allow the system to determine device capabilities before the user requests the larger, bandwidth-intensive file.

4. Key Claim Construction Positions

  • "elements" / "content elements": Petitioner proposed that under the broadest reasonable interpretation, these terms should be construed to mean "digital data included in a message." This broad construction was argued to be supported by the specification and allows various forms of prior art digital data (e.g., icons, thumbnails, videos) to meet this claim limitation.
  • "dereferenced" / "de-referenced": Petitioner proposed this term, found in claims 5, 13, and 20, be construed as "accessing the logic referred to by the link." This construction was based on statements made by the patent applicant during the prosecution of a parent application to overcome an indefiniteness rejection. Petitioner argued this definition links the act of a user clicking an icon or link (as taught in Walters and Irlam) to the execution of the claimed testing and display logic.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-20 of the ’077 patent as unpatentable under 35 U.S.C. §103.