PTAB

IPR2015-00688

Apple Inc v. Summit 6 LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Web Based Media Submission Tool
  • Brief Description: The ’482 patent discloses a web-based media submission tool that performs "intelligent preprocessing" on media objects on a client device before uploading them. The system allows pre-processing parameters to be sent from a remote device (e.g., a server) to the client device to control how the media is modified (e.g., resized, compressed) prior to transmission.

3. Grounds for Unpatentability

Ground 1: Obviousness over Creamer - 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 discloses all elements of the challenged claims. Creamer teaches a portable "Internet camera" (the client device) that connects to the Internet to transmit digital images. Crucially, this camera can download a "full or partial set of operational parameters" from a remote server (an ISP's shell account) to control its operation. These parameters include image processing attributes, such as compression levels. The camera then pre-processes captured images on the device itself—for example, by compressing them into JPEG format—according to the downloaded parameters. Finally, the camera transmits the pre-processed images, along with user identifying information (e.g., User ID and password), to the remote server for publication and viewing on the World Wide Web.
    • Petitioner mapped this disclosure directly to the limitations of the independent claims. For independent claim 13, Creamer’s system was shown to be a method of pre-processing digital content on a client device for subsequent electronic publishing. It receives an identification of digital content (images to be uploaded), pre-processes it at the client device using parameters received from a separate device (the ISP server), and transmits the processed content for publishing.
    • For independent claim 35, Petitioner argued that Creamer’s disclosure of a menu structure for setting parameters would have made the use of a graphical user interface (GUI) to select and pre-process content obvious to a person of ordinary skill in the art (POSA), as GUIs were a conventional interface method.
    • For independent claims 37 (server-side method) and 38 (client-side method), Petitioner contended that Creamer’s client-server architecture, where the camera pre-processes and transmits data that is subsequently distributed by the server, teaches all recited steps.
    • Motivation to Modify (for §103 ground): The petition asserted that because Creamer describes the same type of client-server system for media processing and publication as the ’482 patent, a POSA would have been motivated to implement any minor variations recited in the claims as simple, predictable improvements. The argument is that Creamer provides a complete blueprint, and the claimed features represent nothing more than the use of well-known, conventional techniques within that blueprint. For example, a POSA would find it obvious to include "resizing" (claims 23 and 42) as an operational parameter, as resizing was a common and known form of image pre-processing to reduce file size and transmission time. The motivation was to improve the known system using known solutions.
    • Expectation of Success: A POSA would have had a high expectation of success in making any such modifications. Implementing features like resizing digital content or using a GUI for user input were routine tasks in software engineering at the time and involved the application of known principles in a predictable computing environment.

4. Key Claim Construction Positions

  • "Pre-processing": Petitioner proposed that this term should be construed as "modifying before further processing." Petitioner argued this construction is consistent with the specification's examples, which include resizing, compressing, and changing file formats—all forms of modification performed before the final processing step of uploading and publishing. This construction was central to mapping Creamer's "compression" and other image adjustments to the claimed "pre-processing."
  • "receiving an identification": While not proposing a specific construction, Petitioner argued against Patent Owner's contentions from a related reexamination that the term requires manual selection by a user of a "subset" of images. Petitioner contended that such limitations are not supported by the claim language or specification and that the broadest reasonable interpretation would not exclude automatic identification or selection of all stored images.