PTAB

IPR2015-00806

Google Inc v. Summit 6 LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Web-Based Media Submission Tool
  • Brief Description: The ’482 patent discloses a method and system for pre-processing media objects, such as digital images, on a local client device before transmitting them to a remote server. The specific pre-processing steps are dictated by parameters that the local device receives from a remote device.

3. Grounds for Unpatentability

Ground 1: Claims 12, 13, 16, 18, 19, 21-25, 35-38, 40-42, 44-46, and 49 are obvious over Creamer in view of Aihara.

  • Prior Art Relied Upon: Creamer (6,930,709) and Aihara (6,223,190).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Creamer discloses the core functionality of the challenged claims. Creamer teaches an internet-integrated digital camera (“local device”) that pre-processes images (e.g., compression) according to operational parameters retrieved from a remote destination server, and subsequently transmits the processed images to that server. Petitioner asserted that Aihara, which teaches a digital camera with an LCD screen capable of displaying arrays of four, nine, or sixteen preview images, supplies the claimed feature of displaying a preview image of the selected digital content. The combination of Creamer’s processing and transmission system with Aihara’s user interface for previewing multiple images renders the claims obvious.
    • Motivation to Combine: Petitioner argued that a person of ordinary skill in the art (POSITA) would combine the teachings of Creamer and Aihara by applying a known technique to improve a similar device. A POSITA would have recognized the benefit of incorporating Aihara’s thumbnail array display into Creamer’s internet-connected camera. This modification would improve the user experience by allowing for faster and more efficient review of multiple captured images on the camera’s typically small LCD screen before transmission, which is a predictable and desirable improvement.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in making this combination. Both references operate in the same field of internet-connected digital cameras, and implementing a thumbnail preview display, as taught by Aihara, into the camera system of Creamer would involve well-understood programming techniques for the device's microcontroller.

Ground 2: Claims 12, 13, 16, 18, 19, 21-25, 35-38, 40-42, 44-46, and 49 are obvious over Mayle in view of Narayen.

  • Prior Art Relied Upon: Mayle (6,018,774) and Narayen (6,035,323).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Mayle discloses a client-server system for creating and sending electronic postcards, which meets many claim limitations. Mayle’s system performs pre-processing on a user’s image at the client device (e.g., scaling, compressing into JPEG/GIF format) based on parameters (e.g., byte count limits, fixed postcard size) that would be sent from the server. The processed image is then transmitted to the server. Petitioner argued that Narayen, which discloses a system for creating and publishing digital photo albums, provides the remaining teachings related to album creation and publishing functionalities.
    • Motivation to Combine: Petitioner asserted two primary motivations. First, Mayle itself expressly teaches that its invention could be modified to create "an album...holding a variety of images in a structured album," directly suggesting the combination with a system like Narayen's. Second, a POSITA would combine the references to use a known technique (Narayen’s album authoring) to improve a similar device (Mayle’s image processing system). The combination would predictably result in a system for processing and publishing digital images into a photo album, providing users with convenient, browser-accessible album creation tools.
    • Expectation of Success: A POSITA would expect success in combining these systems. Mayle discloses that its browser-based system can be augmented with programs written in Java. A POSITA could therefore write a Java program to implement Narayen's digital album authoring tools within Mayle's framework to achieve the predictable result of publishing processed digital images to the internet in a photo album format.

4. Key Claim Construction Positions

  • "an amount of media data" / "an amount of digital content": Petitioner proposed that these terms should be construed as "quantity or size of digital content, as defined by one or more of physical dimensions, pixel count, or kilobytes." This construction was argued to be critical for demonstrating that the prior art’s teachings of setting compression levels, resolution, or file size limits meet the claim limitation of receiving pre-processing parameters specifying an "amount" of data.
  • "publication" / "distribution": Petitioner proposed the construction "making available to at least one person other than the user." This broad construction was asserted to encompass the prior art methods of transmitting an image from a client device to a server or sending an electronic postcard to a recipient, which might not meet a narrower definition of "making publicly available."
  • "said identification": For claim 18, Petitioner argued that the ambiguous term "said identification" should be construed as "said identification of digital content." This construction resolves a potential antecedent basis issue and clarifies that the pre-processing parameters are stored in memory prior to the identification of the specific digital content to be processed.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 12, 13, 16, 18, 19, 21-25, 35-38, 40-42, 44-46, and 49 of the ’482 patent as unpatentable under 35 U.S.C. §103.