PTAB

IPR2015-00684

Apple Inc v. Summit 6 LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method, System and Computer Program Product for Photo and Video Capture and Distribution
  • Brief Description: The ’515 patent describes methods and systems for pre-processing digital content on a client device before uploading it to a server. A software component, such as a Java Applet running in a browser, receives pre-processing parameters from a server and modifies content (e.g., via format conversion, resizing, or compression) to meet server requirements or bandwidth constraints before transmission.

3. Grounds for Unpatentability

Ground 1: Obviousness over Shaffer - Claims 1, 2, 5, 7, 11, 18, 19, 21-23, 26, 29, 30, 38-41, and 52 are obvious over Shaffer.

  • Prior Art Relied Upon: Shaffer (Patent 6,092,114).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shaffer, which describes a client-server electronic messaging system, discloses or renders obvious every limitation of the challenged claims. Independent claim 21, a server-side method, is allegedly met by Shaffer’s disclosure of a local server receiving a message with a pre-processed attachment from a remote client device. Shaffer’s system sends instructions (the claimed “pre-processing parameters”) from a server to a client, triggering an “automatic conversion and retransmission of the attachment” if the servers cannot perform the conversion themselves. This client-side conversion is the claimed “pre-processing.” Independent claim 1, a client-side method, is the other side of this same transaction. Petitioner contended that other limitations, such as account access conditioned on an identifier, were obvious modifications, as Shaffer’s system was based on conventional messaging servers which commonly required user identity verification via password. For dependent claims, Petitioner asserted Shaffer’s discussion of converting between video formats (e.g., AVI to MPEG) inherently involves resizing or compressing files, and its teaching that client devices can be "any device that is used to access email" would have included then-common web-browser email clients.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the motivation was to apply or modify Shaffer’s own teachings. Petitioner argued a person of ordinary skill in the art (POSA) would have been motivated to implement Shaffer’s messaging system using well-known, conventional techniques, such as requiring a username and password for account access, to improve security and functionality. Such a modification was argued to be a predictable improvement, not an inventive step.
    • Expectation of Success (for §103 grounds): A POSA would have had a high expectation of success in implementing standard features like user authentication or using a web-based client within Shaffer's system, as these were common and well-understood technologies at the time.

Ground 2: Obviousness over Shaffer and NeXTSTEP - Claims 6, 28, and 53 are obvious over Shaffer in view of NeXTSTEP.

  • Prior Art Relied Upon: Shaffer (Patent 6,092,114) and NeXTSTEP (NeXTSTEP Applications Manual (1990)).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds the limitation of “displaying a thumbnail preview” of the media files to the system disclosed by Shaffer. Petitioner argued that Shaffer teaches a general messaging system where the client can be “any device,” and NeXTSTEP explicitly discloses an email client application from that era that displays thumbnail previews of message attachments. The combination of Shaffer’s messaging framework with NeXTSTEP’s specific user interface feature was alleged to render the claims obvious.
    • Motivation to Combine (for §103 grounds): A POSA would combine these references to improve the user experience of Shaffer’s messaging system. Displaying thumbnails was a known and desirable feature for managing email attachments, making it an obvious and predictable feature to add to any email client. Since Shaffer’s system was designed for any email access device, incorporating a well-known GUI feature like that in NeXTSTEP would have been a straightforward design choice to make the system more user-friendly.
    • Expectation of Success (for §103 grounds): Integrating a known GUI feature like thumbnail previews into an email application was a routine task for a software engineer at the time, leading to a high expectation of success.

4. Key Claim Construction Positions

  • "Pre-processing": Petitioner proposed this term should be construed as "modifying before further processing." This construction was important for mapping the term to Shaffer’s disclosure of file format conversion that occurs on a client device before the file is retransmitted.
  • "Host server": Petitioner proposed construing this term as "a device or server that provides access to data or programs."
  • "computer readable program code means..." (Claim 39): Petitioner noted this means-plus-function term, with a function of “enabling a receipt of an identification of one or more image files... to associate with said account.” While arguing the patent lacks adequate structure, Petitioner contended that to the extent structure is disclosed, Shaffer teaches the same structure and function.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1, 2, 5-7, 11, 18, 19, 21-23, 26, 28-30, 38-41, 52, and 53 of Patent 8,612,515 as unpatentable.