PTAB

IPR2015-00807

Google Inc v. Summit 6 LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Improved Web-Based Media Submission Tool
  • Brief Description: The ’515 patent discloses a system and method for media submission. The technology involves a client device that pre-processes digital content, such as images, based on parameters received from a remote server before transmitting the processed content to another device.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 6, 10, 11, 18, 19, 20, 23, 26, 28, 29, 30, 38, and 39 are obvious over Creamer in view of Aihara.

  • Prior Art Relied Upon: Creamer (Patent 6,930,709) and Aihara (Patent 6,223,190).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Creamer, which discloses an integrated Internet camera, teaches the core limitations of independent claims 1 and 23. Specifically, Creamer's camera transmits a user ID and password to access a remote shell account (meeting the "access an account" limitation), allows a user to select images for upload (meeting the "receiving an identification" and "confirmation of intent" limitations), and pre-processes images using a "compression engine." This pre-processing is controlled by a downloadable setup/configuration file from the remote server containing parameters for JPEG compression, resolution, and cropping (meeting the "pre-processing...using parameters received from a remote server" limitation). Finally, Creamer's camera transmits the processed JPEG files to the server via FTP. For the dependent claims, Petitioner asserted that Aihara, which discloses a digital camera with an LCD screen, supplies the missing elements. Aihara explicitly teaches a "play mode" that can display previously captured images in "arrays of four, nine, or sixteen smaller preview images," directly teaching the thumbnail preview feature of claims 6 and 28.
    • Motivation to Combine: A POSITA would combine Creamer and Aihara to improve the user experience of Creamer's Internet-connected camera. Petitioner argued that applying Aihara’s known technique of displaying thumbnail arrays on an LCD screen to Creamer’s camera system would be a simple and predictable modification. This would allow users to more easily and efficiently review multiple captured images on a relatively small handheld display before committing to a potentially slow or costly transmission.
    • Expectation of Success: The petition argued that a skilled artisan would have a high expectation of success in this combination. Both references operate in the same field of digital cameras with network connectivity and displays, making the integration of a known display feature (thumbnail arrays) into a base system straightforward and predictable.

Ground 2: Claims 1, 2, 6, 10, 11, 18, 19, 20, 23, 26, 28, 29, 30, 38, and 39 are obvious over Mayle in view of Narayen.

  • Prior Art Relied Upon: Mayle (Patent 6,018,774) and Narayen (Patent 6,035,323).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Mayle, which describes a client-server system for creating and sending an "electronic postcard," teaches the fundamental client-side processing claimed. Mayle's system performs pre-processing such as formatting, scaling, and compressing on the client device based on parameters (e.g., maximum byte count, fixed postcard size) before transmission. The petition argued it would be obvious for these parameters to be sent from the server hosting the postcard application to the client's browser. Narayen was presented as teaching a system for creating and publishing digital photo albums. Narayen teaches user login to a server, selection of images to create a media container, scaling images to fit a layout, and publishing the album to the Internet. The combination of Mayle's client-side processing based on server rules and Narayen's album creation and user account features was argued to render all challenged claims obvious.
    • Motivation to Combine: The primary motivation asserted was an explicit suggestion within Mayle that its "invention can be modified to create...an album...holding a variety of images." A POSITA, reading this, would have been directly motivated to look to known album-creation technologies like Narayen to implement this suggested improvement. Combining Narayen's album authoring tools with Mayle’s image processing system was therefore argued to be a direct response to a recognized need and an explicit suggestion in the primary reference, not a product of hindsight.
    • Expectation of Success: Petitioner asserted a skilled artisan could readily code and implement the album features of Narayen into Mayle's client system with a predictable result. This would achieve the desired goal of publishing processed digital images in a photo album format on the Internet, a straightforward software integration task.

4. Key Claim Construction Positions

  • The petition argued for a specific construction of the term "distributing" as it appears in claims 1 and 23. Based on the patent's description of "manipulating and sharing digital images over the Internet," Petitioner asserted the broadest reasonable construction for "distributing" is at least "making available to at least one person other than the user." This construction is important for mapping prior art that involves making images available for viewing by others.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 2, 6, 10, 11, 18, 19, 20, 23, 26, 28, 29, 30, 38, and 39 of the ’515 patent as unpatentable under 35 U.S.C. §103.