PTAB

IPR2015-01000

Amazon.com Inc v. SimpleAir Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: SYSTEM AND METHOD FOR TRANSMISSION OF DATA
  • Brief Description: The ’914 patent discloses a system for providing message arrival notifications to users of computers that may be online or offline. The system uses a wireless broadcast network (e.g., a pager network) to send notifications, which is separate from the data connection (e.g., the Internet) used to retrieve the full message content.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hays and Pepe - Claims 1-3, 7, 14, and 67-69 are obvious over Hays in view of Pepe.

  • Prior Art Relied Upon: Hays (U.S. Patent Application No. 08/215,817) and Pepe (Patent 5,742,905).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hays taught the core concept of the ’914 patent: a telecommunication system that transmits messages to a mobile device via two separate channels, a cellular phone channel and a paging channel, allowing notification even when the primary cellular connection is unavailable (offline). Hays’s system included transmitting data from information sources (e.g., stock tickers) to a central server (message manager and UMS), preprocessing the data, and broadcasting it to devices regardless of their online/offline status. Pepe was argued to supply teachings on parsing messages and using a subscriber database to translate email messages into a format suitable for a paging network.
    • Motivation to Combine: A POSITA would have been aware of both references, which address similar technologies in cellular and pager messaging. Petitioner asserted a POSITA would combine Hays's system with Pepe's more detailed implementation of subscriber databases and message protocol translation to predictably enhance the functionality and efficiency of converting messages for transmission over a paging network.
    • Expectation of Success: The combination involved applying known techniques (Pepe's database and translation logic) to a known system (Hays's dual-channel messaging) to achieve a predictable result.

Ground 2: Obviousness over Hays, Pepe, and Throckmorton - Claims 9-13, 16-20, 22-26, 50, 64, 65 and 71 are obvious over Hays and Pepe in view of Throckmorton.

  • Prior Art Relied Upon: Hays (Application # 08/215,817), Pepe (Patent 5,742,905), and Throckmorton (Patent 5,818,441).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Hays and Pepe by adding the teachings of Throckmorton. Petitioner argued Throckmorton disclosed a system for interactive communications that provides additional data associated with a primary broadcast, such as a URL pointing to a secondary source of information. Throckmorton specifically taught embedding URLs into data streams and sending commands to cause the immediate display of associated data, enabling a user to click a link to launch a browser and retrieve more information. This was alleged to teach the limitations in claims like claim 9, which required attaching an "Internet address location" to the preprocessed data for providing an automatic connection back to the information source.
    • Motivation to Combine: A POSITA, having combined Hays and Pepe to create an efficient offline notification system, would be motivated to incorporate Throckmorton's teachings to add the highly desirable and predictable feature of interactive links (URLs) within the notifications. This would allow users to easily access detailed information related to the alert, a straightforward improvement to the user experience.
    • Expectation of Success: Integrating URL functionality as taught by Throckmorton into the messaging system of Hays/Pepe was presented as a predictable integration of known technologies.

Ground 3: Obviousness over Kane, Hays, and Throckmorton - Claims 1-3, 7, 9-13, 16-20, 22-26, 50, 64, 65, 67-69, and 71 are obvious over Kane in view of Hays and Throckmorton.

  • Prior Art Relied Upon: Kane (Patent 5,487,100), Hays (Application # 08/215,817), and Throckmorton (Patent 5,818,441).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Kane as an alternative primary reference that disclosed a system for transmitting information through two channels: a wireless paging network and a dial-up PSTN connection. Kane’s central terminal received information from multiple sources (including X.400 email), created a "message record" (preprocessing), converted email addresses to pager addresses using a subscriber database, and transmitted notifications over the paging network. Petitioner argued Kane alone taught most limitations of claim 1. Hays was added for its teachings on instantaneous delivery to devices regardless of their online/offline status, and Throckmorton was added for its teachings on embedding URLs for one-click access to further information, as detailed in Ground 2.
    • Motivation to Combine: A POSITA would combine the teachings of Hays with Kane to improve the message delivery mechanism, ensuring notifications were delivered instantaneously. Similarly, a POSITA would incorporate Throckmorton's URL functionality into Kane's system for the same reasons as in Ground 2: to provide a predictable enhancement allowing users to easily retrieve detailed information.
    • Expectation of Success: The combination involved integrating known, complementary features from Hays and Throckmorton into the foundational system disclosed by Kane, which would have been a predictable and successful endeavor for a POSITA.

4. Key Claim Construction Positions

  • data channel associated with each device: Petitioner argued this term should be construed as "a path through which the device connects to the Internet or other online service." This construction was central to mapping prior art systems that used general-purpose connections like cellular or dial-up networks to retrieve full message content.
  • central broadcast server: Petitioner argued for a construction of "one or more servers that transmit data packets over a wireless broadcast network to both on- and off-line computers." This supported the argument that prior art systems like Hays's "message manager" and UMS, or Kane's "central terminal," met the limitation.
  • information gateway / transmission gateway: Petitioner adopted the patent owner's proposed constructions for these terms, which broadly defined them as software programs performing functions like building data blocks and preparing them for transmission. Petitioner argued that under these broad constructions, the software-based message processing and routing functions in the prior art clearly met the limitations.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 7, 9-14, 16-20, 22-26, 50, 64, 65, 67-69, and 71 of Patent 7,035,914 as unpatentable under 35 U.S.C. §103.