PTAB

IPR2015-00740

WhatsApp Inc v. TriPlay Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Messaging System and Method
  • Brief Description: The ’475 patent describes a messaging system that adapts an initial message from an originating device for delivery to a destination device. The system selects and converts the message format and layout based on criteria such as the destination device's communication or display capabilities.

3. Grounds for Unpatentability

Ground 1: Obviousness over Coulombe - Claims 1, 12, 23, 37, 39, & 41 are obvious over Coulombe.

  • Prior Art Relied Upon: Coulombe (Application # 2003/0236892).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Coulombe, which discloses a system for adapting messages to conform to a recipient's terminal capabilities, teaches every limitation of the independent claims. Coulombe’s "SIP Proxy/Registrar" was mapped to the claimed "access block," as it receives messages from an originating device and transmits them to a destination device. Coulombe’s "Message Adaptation Engine" was mapped to the claimed "media block," as it is operatively coupled to the registrar and is responsible for adapting messages. Petitioner asserted that Coulombe explicitly discloses selecting and converting message format and layout based on the three criteria recited in claim 1: (i) communication capabilities (e.g., maximum supported message size), (ii) display capabilities (e.g., adapting layout for landscape vs. portrait orientation), and (iii) communication media (e.g., network characteristics). The argument for obviousness was based on direct disclosure, asserting that Coulombe's system performs the same functions for the same purpose as the claimed invention.
    • Motivation to Combine: Not applicable (single reference ground).
    • Expectation of Success: Not applicable (single reference ground).

Ground 2: Obviousness over Coulombe, Druyan, and Tittel - Claims 6, 9, 17-18, 28, 40, & 42 are obvious over Coulombe in view of Druyan and Tittel.

  • Prior Art Relied Upon: Coulombe (Application # 2003/0236892), Druyan (Patent 6,928,617), and Tittel (a 1997 book titled More HTML for Dummies).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed the dependent claims, which add limitations related to a message layout "based on a template" having a "unique identifier." Petitioner argued Coulombe teaches the base system, while Druyan and Tittel supply the template limitations. Druyan discloses a method for adapting HTML content for devices with small screens using a "master style sheet" file (the template) that specifies the layout. Tittel, cited as evidence of the state of the art, taught that style sheets were fundamental web technology and were referenced using a <LINK> tag containing a Uniform Resource Locator (URL), which serves as a unique identifier. The combined art, therefore, taught a system that receives a message (Coulombe) with a layout based on a template (Druyan's style sheet) identified by a unique URL (Tittel), and recognizes that identifier to perform layout conversions based on predefined rules (Druyan's derivative style sheets) corresponding to the destination device's display capabilities.
    • Motivation to Combine: Petitioner argued a POSITA would combine these references to solve a known problem. Coulombe and Druyan address the analogous problem of converting content for display on devices with different capabilities. Because Coulombe's system could process XHTML (a form of HTML), a POSITA would have found it obvious to apply the well-known style sheet techniques from Druyan and Tittel to manage the layout of such messages. Tittel provided express motivation, explaining that external style sheets (identified by a unique URL) offer reusability and create a uniform look, benefits a POSITA would have sought to incorporate into Coulombe's messaging system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining standard, well-documented web layout technology (style sheets from Druyan and Tittel) with a message adaptation system (Coulombe) involved applying known techniques for their intended purpose and would have yielded predictable results.

4. Key Claim Construction Positions

  • "Access Block" / "Media Block": Petitioner argued that based on the specification, functional "blocks" should be construed broadly as "software and/or hardware for performing the function of the block." For "access block," the function is facilitating access to communication devices. For "media block," the function is processing messages, including selecting format/layout and converting the message. This construction prevents the terms from being limited to a specific hardware structure.
  • "Template": The specification defines a "message template" as "any kind of predefined user interface related to content and/or layout of transmitted and/or received message." Petitioner adopted this broad construction, arguing it encompassed technologies like the "style sheets" disclosed in the prior art, which are predefined files that dictate content layout.

5. Relief Requested

  • Petitioner requests institution of inter partes review of claims 1, 6, 9, 12, 17-18, 23, 28, 37, and 39-42 of the ’475 patent and a finding that those claims are unpatentable.