PTAB

IPR2015-00681

Twitter Inc v. Summit 6 LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Web-based media submission tool
  • Brief Description: The ’557 patent discloses a system for uploading media content to a website. The purported invention is a web-based tool that performs client-side, configurable "intelligent preprocessing" on media objects (e.g., images) before uploading them, thereby ensuring the media meets the requirements of the destination website.

3. Grounds for Unpatentability

Ground 1: Obviousness over MedJava and Walnum - Claims 28, 29, and 33 are obvious over MedJava in view of Walnum.

  • Prior Art Relied Upon: MedJava (a 1998 USENIX conference paper titled "The Design and Performance of MedJava") and Walnum (a 1996 instructional book titled "Java By Example").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that MedJava, a "general purpose imaging tool," disclosed the core elements of independent claim 28. MedJava described a Java applet (the "media object identifier") embedded in a website that allows a user to select images ("media objects") and preprocess them by converting them to GIF format for upload to a server. This conversion, which involves changing the file format and compressing the data, met the "pre-processing" limitation and was performed to satisfy server requirements ("for the requirements of the third-party web site") and automatically ("without user selection"). Walnum was cited to teach that modifying a Java applet to access local files instead of only remote files was a trivial, well-known modification, addressing any potential distinction that MedJava focused on images from remote servers.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to apply Walnum's teachings to MedJava's applet because MedJava was described as a general-purpose tool, and enabling it to access local files was a predictable and desirable extension of its functionality.
    • Expectation of Success: As Walnum taught that the modification required changing only a single line of code in the codebase attribute, a POSITA would have had a high expectation of success.

Ground 2: Obviousness over MedJava, Walnum, and Creamer - Claims 34, 35, and 36 are obvious over MedJava in view of Walnum, and further in view of Creamer.

  • Prior Art Relied Upon: MedJava, Walnum, and Creamer (Patent 6,930,709).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the MedJava/Walnum combination to address the limitations of dependent claims 34-36, which required the media object identifier to be "configurable to control the pre-processing." While MedJava taught "dynamically configured" image filters, Petitioner introduced Creamer to provide more explicit teachings. Creamer disclosed a network camera that pre-processed images according to parameters (e.g., scaling, compression, cropping) received from a configuration file on a web server. This showed pre-processing that was configurable by the website operator to meet specific presentation requirements.
    • Motivation to Combine: A POSITA would combine Creamer's teachings with the MedJava/Walnum system to enhance its capabilities. Incorporating a wider variety of configurable pre-processing parameters from Creamer into MedJava's "general purpose imaging tool" was a logical step to better conform uploaded images to a website's specific needs, a known design goal.
    • Expectation of Success: Since the MedJava system already included configurable elements (image filters), adding further well-known configurable parameters as taught by Creamer was a predictable improvement with a reasonable expectation of success.

Ground 3: Obviousness over MedJava, Walnum, and Mattes - Claims 37, 38, and 41 are obvious over MedJava in view of Walnum, and further in view of Mattes.

  • Prior Art Relied Upon: MedJava, Walnum, and Mattes (Patent 6,038,295).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed independent claim 37, which added a "file reduction" limitation requiring the system to check a media object's file size and reduce it if it exceeded a predetermined maximum. Petitioner argued that the MedJava/Walnum combination inherently performed file size reduction via GIF compression. To strengthen the argument, Mattes was introduced as explicitly teaching a system that checked image quality (a proxy for file size) against server requirements and could request a lower-quality, smaller file if the submitted one was too large.
    • Motivation to Combine: A POSITA would combine Mattes's file-size check with the MedJava/Walnum system to achieve the well-understood benefit of reduced bandwidth usage. Because MedJava's applet already performed compression based on server specifications, integrating an explicit file-size check as taught by Mattes was a common-sense improvement.
    • Expectation of Success: Implementing a file size check and adjusting compression parameters to meet a target size was a routine task for a software engineer at the time, ensuring a high expectation of success.
  • Additional Grounds: Petitioner asserted a final ground that claims 42-44 were obvious over MedJava, Walnum, and Mattes, further in view of Creamer. This ground argued it would have been obvious to add the configurability features taught by Creamer (as argued in Ground 2) to the file-size-reducing system of Ground 3.

4. Key Claim Construction Positions

  • "pre-processing": This term was central to Petitioner's arguments. Petitioner argued for a construction of "modifying before further processing." This construction was proposed in contrast to a narrower district court construction that required the modification to be "in preparation for transmission to a remote device." Petitioner contended its broader construction was more consistent with the specification, which listed examples like cropping an image that could be for purposes other than just preparing for transmission.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 28-29, 33-38, and 41-44 of the ’557 patent as unpatentable.