PTAB

IPR2015-00688

Apple Inc. v. Summit 6, LLC

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1. Case Identification

2. Patent Overview

  • Title: Web Based Media Submission Tool
  • Brief Description: The ’482 patent discloses a web-based tool for media submission that is configurable to perform "intelligent preprocessing" on media objects on a client device before uploading them. The system comprises a media object identifier, which selects and processes media like digital images using client-side intelligence, and a media sender, which transmits the processed content to a server.

3. Grounds for Unpatentability

Ground 1: Claims 13, 14, 16-23, 35, 37, 38, 40-42, 44-46, and 49 are obvious over Creamer.

  • 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, standalone internet-connected camera, teaches every element of the challenged claims. The core method of independent claim 13 involves pre-processing digital content on a client device for subsequent electronic publishing based on parameters received from a separate device. Petitioner asserted that Creamer’s camera functions as the claimed client device. It pre-processes images (e.g., by compression) using its internal compression engine. Critically, Creamer taught that the camera could download a "full or partial set of operational parameters" from a remote server (a shell account on an ISP), which dictates how the pre-processing occurs. These parameters, such as JPEG compression levels, place the digital content into a "specified form" (JPEG) in preparation for publication.
    • Petitioner further mapped that Creamer’s camera transmits the pre-processed (compressed) images to the server for publication, viewable by remote users. The transmission includes retrieved user authentication information (user ID and password) that is stored on the client device, satisfying limitations regarding retrieving user identification and transmitting it with the processed content.
    • The arguments for dependent claims were based on specific disclosures in Creamer. For example, claim 14 (compressing/reducing file size) and claim 23 (resizing content) were mapped to Creamer's disclosure that its camera’s microcontroller can compress images to various JPEG levels and adjust image resolution. Claims 16 and 18, requiring parameters to be previously downloaded and stored in memory, were mapped to Creamer's teaching that operational parameters are downloaded from the server and stored in the camera's NVRAM prior to processing.
    • Arguments for other independent claims (35, 37, and 38) relied on the same fundamental teachings. Claim 35 adds a graphical user interface (GUI) element, which Petitioner argued Creamer disclosed as a possible interface for controlling the camera. Claim 37 recites the method from the server's perspective, which Petitioner argued was inherent in Creamer’s client-server architecture where the ISP server receives the pre-processed content from the camera. Claim 38 was presented as substantially similar to claim 13.
    • Motivation to Modify (for §103 grounds): As a single-reference obviousness challenge, the motivation was framed as the application of conventional techniques to a known system. Petitioner contended that both the ’482 patent and Creamer are directed to the same type of device and solve the same problem: client-side processing of media for efficient web uploading. Therefore, a person of ordinary skill in the art (POSA) would have found it obvious to apply or modify the specific features disclosed in Creamer (like using a GUI or adjusting resolution as an operational parameter) to achieve the claimed invention. No significant combination or invention was required, only the implementation of known, predictable solutions disclosed within Creamer itself.
    • Expectation of Success: Petitioner asserted a POSA would have had a high expectation of success. Creamer described a functioning system that already performed the core claimed steps of downloading parameters, pre-processing content on a client, and uploading it. Modifying this existing system with other features also disclosed within Creamer, such as specific pre-processing steps like resizing, would have yielded predictable results.

4. Key Claim Construction Positions

  • "Pre-processing": Petitioner argued this term should be construed broadly as “modifying before further processing.” This construction was central to their argument that various modifications taught by Creamer (e.g., compression, resizing) fall within the scope of the claims. Petitioner noted this contrasts with the Patent Owner’s narrower interpretation, which attempted to limit the term to only compressing an image for publication. Petitioner highlighted that the Examiner in a related ex parte reexamination had rejected the Patent Owner's narrower construction.
  • "receiving an identification": Petitioner contended that this phrase does not require manual user input, as argued by the Patent Owner in other proceedings. The petition pointed to other claims in the ’482 patent that explicitly recite a "click command," suggesting that where manual input was intended, it was expressly claimed. Therefore, Creamer’s automated identification of files to upload based on stored attributes met this limitation under the broadest reasonable interpretation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 13, 14, 16-23, 35, 37, 38, 40-42, 44-46, and 49 of Patent 7,765,482 as unpatentable.