PTAB

IPR2015-00683

Apple Inc v. Summit 6 LLC

Key Events

Petition

petition Intelligence

Title: Media file pre-processing
Brief Description: The ’515 patent discloses methods, systems, and devices for pre-processing media files on a client device before uploading them to a remote server. The system uses a software component, such as a Java Applet, which receives pre-processing parameters from the server to modify content (e.g., resizing, compression) to meet server requirements or bandwidth constraints.

Prior Art Relied Upon: Creamer (Patent 6,930,709).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Creamer, which discloses a portable, networked digital camera, teaches all elements of the challenged claims from both a client-side and server-side perspective. For server-side independent claim 21, Creamer’s local ISP server receives account access information (user ID/password) from the camera (client device), transmits operational parameters (the claimed pre-processing parameters) to the camera, and then receives and stores the pre-processed images uploaded from the camera. For client-side independent claim 1, Creamer’s camera transmits account information to the server, receives pre-processing parameters, pre-processes media files according to those parameters (e.g., color adjustment, compression, resizing), and transmits the pre-processed files to the server. Dependent claims were argued to be obvious as they recited features also disclosed in Creamer, such as resizing images, transmitting location information via TCP/IP headers, and reporting transmission status via email.
- Motivation to Combine (for §103 grounds): As this ground relied on a single reference, Petitioner’s rationale was that Creamer itself discloses or suggests all claimed features, making their implementation an obvious application of its teachings for a person of ordinary skill in the art (POSITA).

Prior Art Relied Upon: Creamer (Patent 6,930,709) and Anderson '122 (Patent 6,567,122).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Creamer taught the base method of claim 1, upon which claim 5 depends. The additional limitation of claim 5, "receiving an identification [of files to upload] comprises receiving via a web browser user interface," was allegedly taught by Anderson ’122. Anderson ’122 discloses a digital camera system featuring a web page interface that provides a "readily familiar and intuitive interface" for user interaction and control of the camera, including modifying parameters.
- Motivation to Combine (for §103 grounds): A POSITA would combine Anderson ’122’s web interface with Creamer’s networked camera system to provide a more user-friendly and intuitive method for users to select files and configure upload parameters. Anderson ’122 was asserted to provide an express motivation for this combination by teaching that its web interface is "intuitively easy to utilize" for new users.
- Expectation of Success: A POSITA would have expected success in this combination because it involved implementing a known and conventional user interface (a web browser GUI) with a known networked camera system to achieve the predictable result of improved usability.

Prior Art Relied Upon: Creamer (Patent 6,930,709) and Anderson '480 (Patent 6,118,480).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Creamer taught the base methods and systems of claims 1, 23, and 52, from which the challenged claims depend. The additional limitation of displaying a "thumbnail preview" of the identified media files was allegedly taught by Anderson ’480. Anderson ’480 discloses a digital camera that displays thumbnail previews on its LCD screen, describing them as navigational aids that represent "small-sized versions of the captured images" and address a recognized problem with conventional interfaces that can only display full-size images.
- Motivation to Combine (for §103 grounds): A POSITA would combine Anderson ’480’s thumbnail preview feature with Creamer’s camera system to improve the user experience. Anderson ’480 was argued to explicitly motivate this combination by identifying the disadvantage of being able to display only full-size images and presenting its thumbnail navigation technique as a solution that "addresses such a need."
- Expectation of Success: A POSITA would have expected success because adding a known display feature like thumbnail previews to a digital camera was a well-understood and predictable improvement for enhancing file navigation and selection.

“Pre-processing”: Petitioner proposed this term be construed as “modifying before further processing.”
“Host server”: Petitioner proposed this term be construed as “a device or server that provides access to data or programs.”
“Remote server”: Petitioner proposed this term be construed as “a device or server that is not co-located with the client device.”
“A distributing party”: Petitioner proposed this term be construed as “a party that distributes the pre-processed content to one or more recipient devices.”
Means-Plus-Function (Claim 39): For the term “computer readable program code means... for enabling a receipt of an identification... to associate with said account,” Petitioner argued that even if the patent discloses sufficient structure, Creamer discloses the same structure (e.g., integrated camera program code and readable medium like NVRAM) performing the identical function.

Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 5-7, 11, 18-19, 21-23, 26, 28-30, 38-41, and 52-53 of Patent 8,612,515 as unpatentable.