PTAB

IPR2015-00685

Apple Inc v. Summit 6 LLC

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Web Based Media Submission Tool
  • Brief Description: The ’482 patent describes a system for submitting media from a client device to a server. The system is configurable to perform a variable amount of "intelligent preprocessing" on media objects (e.g., digital images) on the client side before they are uploaded, based on parameters received from a remote server.

3. Grounds for Unpatentability

Ground 1: Obviousness over Creamer - Claims 1, 4, 6, 8, 10, 12, 25, and 51 are obvious over Creamer.

  • Prior Art Relied Upon: Creamer (Patent 6,930,709).

  • Core Argument for this Ground: Petitioner argued that Creamer discloses all elements of the challenged claims. Although Petitioner asserted that Creamer anticipates the claims, the challenge was presented as obviousness under 35 U.S.C. §103 to account for any minor differences or the potential need for expert corroboration. The core of the argument was that Creamer’s system, a portable Internet camera, performs the same fundamental functions as the ’482 patent: it receives processing parameters from a remote device, pre-processes digital content on the client device according to those parameters, and transmits the pre-processed content for remote distribution. Any minor differences between Creamer’s disclosure and the claims would have been obvious modifications to a person of ordinary skill in the art (POSA).

    • Prior Art Mapping: Petitioner asserted that Creamer teaches the key limitations of the independent claims as follows:

      • Claims 1, 12, 25 (Client-Side Method): Creamer’s standalone Internet camera functions as the claimed "client device." It performs a "computer implemented method of pre-processing" by compressing digital images before transmitting them for "subsequent electronic publishing."
      • Receiving Parameters: Creamer’s camera receives a "full or partial set of operational parameters" from a remote server (a shell account on an ISP). These parameters, which control image compression, resolution, and other attributes, correspond to the claimed "pre-processing parameters." The parameters include specifications of an "amount of digital content," such as by setting one of four JPEG compression levels or using an "ADAPTIVE" parameter to adjust compression based on data transmission rates, thereby affecting the final file size.
      • Identifying and Transmitting Content: Creamer discloses an "IMAGE FILES" menu that allows a user to set attributes to identify which images are to be uploaded, satisfying the "receiving an identification of a group of...digital content" limitation. The camera then transmits the pre-processed (compressed) images to a server device, which makes them available on a web page for viewing by remote users. This maps to the limitations of transmitting the content for subsequent publication to remote devices.
      • Claim 51 (Server-Side Method): Petitioner argued Creamer also teaches the server-side perspective claimed in claim 51. Creamer’s server (ISP) receives the pre-processed digital content from the client device (the camera) and publishes it via an electronic network (the Internet) to remote devices (personal computers with web browsers).
      • Dependent Claims: Petitioner mapped dependent claim limitations to specific disclosures in Creamer, including reducing file size (claim 6) through compression, resizing digital content (claim 10) by adjusting resolution, and transmitting identifying information (claim 8) via JPEG header data.

    • Motivation to Combine (Modify): As a single-reference ground, the motivation focused on modifying Creamer’s teachings. Petitioner contended that a POSA would have been motivated to make any minor modifications to Creamer's system to achieve the claimed invention. For example, modifying Creamer’s compression scheme (used to manage bandwidth) for the purpose of publication would have been a simple design choice to achieve predictable results using well-known techniques.

    • Expectation of Success: Petitioner argued that a POSA would have had a high expectation of success in implementing any such modifications. The techniques described, such as image compression, resizing, and client-server communication for parameter exchange, were all well-established in the art at the time of the invention.

4. Key Claim Construction Positions

  • "Pre-processing": Petitioner argued this term should be construed as "modifying before further processing." This broad construction was central to the invalidity argument, as it allowed Creamer's disclosure of compressing images before transmission to be mapped to the "pre-processing" limitation of the claims. Petitioner noted that the Patent Owner had argued for a narrower construction in a related reexamination, which was rejected by the Examiner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 4, 6, 8, 10, 12, 25, and 51 of the ’482 patent as unpatentable.