PTAB

IPR2015-01321

Bungie Inc v. Worlds Inc

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Enabling Users to Interact in a Virtual Space
  • Brief Description: The ’998 patent describes a client-server network system that allows multiple users, represented by avatars, to interact in a shared 3D virtual world. The system's key feature is server-based filtering, where the server provides a client with positional updates for only a subset of other users (e.g., those within a certain proximity or field of view), reducing the processing load on the client computer.

3. Grounds for Unpatentability

Ground 1: Obviousness over Funkhouser and Marathon - Claims 1-3, 7-8, 11-12, 16, 18, and 20

  • Prior Art Relied Upon: Funkhouser (“RING: A Client-Server System for Multi-User Virtual Environments,” 1995) and Marathon (a 1994 computer game manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Funkhouser taught the core limitations of the independent claims, including a client-server architecture for a multi-user 3D virtual environment. Crucially, Funkhouser disclosed server-side filtering (“server-based message culling”) based on line-of-sight visibility, where a client processor receives positional and orientation updates for "less than all" of the remote user avatars. Funkhouser, however, did not explicitly teach switching the display perspective to that of another user. Petitioner asserted that Marathon, a popular multiplayer game, disclosed this missing feature, explicitly teaching that a player could "switch views to the other players in the game by pressing the delete key."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings to improve the user experience of the system disclosed in Funkhouser. Funkhouser’s system was expressly suited for multiplayer games, and Marathon provided a well-known, desirable feature for such games. Combining Marathon’s client-side perspective-switching with Funkhouser’s optimized server-side filtering was a logical step to create a more feature-rich and enjoyable, yet scalable, virtual environment.
    • Expectation of Success: The combination was predictable. Adding the client-side perspective-switching feature from Marathon would be complementary to, and would not interfere with, the server-based message filtering disclosed in Funkhouser. The server would still filter and send data for a subset of avatars, and the client would then process that received data to display different perspectives.

Ground 2: Obviousness over Funkhouser, Marathon, and Sitrick - Claim 3

  • Prior Art Relied Upon: Funkhouser, Marathon, and Sitrick (Patent 4,521,014).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Funkhouser and Marathon combination to address dependent claim 3, which required a "custom avatar created based on input from the local user." Petitioner argued that to the extent Funkhouser and Marathon did not explicitly disclose user-input-based avatar customization, Sitrick did. Sitrick described a networked multi-player gaming system where a user could select a "distinguishable visual image representation," including customizing its "color, size, or shape," creating an original image, or even using a "digitized image of each user's face."
    • Motivation to Combine: A POSITA would have found it obvious to incorporate the consumer-friendly avatar customization feature from Sitrick into the virtual environment of Funkhouser and Marathon. This addition was a known method for enhancing player engagement and personalization in multiplayer games and was a logical feature to add to the base system.

Ground 3: Obviousness over Funkhouser, Marathon, and Funkhouser '93 - Claims 13-15

  • Prior Art Relied Upon: Funkhouser, Marathon, and Funkhouser '93 (“Adaptive Display Algorithm for Interactive Frame Rates During Visualization of Complex Virtual Environments,” 1993).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Funkhouser '93 to the primary combination to teach the limitations of claims 13-15, which involved limiting the number of remote avatars displayed based on "computing resources available" or a "selection made by the local user." Funkhouser '93 taught an "adaptive display algorithm" to maintain a target frame rate by adjusting image quality. This included reducing object detail or omitting objects from the display entirely, based on a cost/benefit analysis tied to the computer's performance capabilities and a "user-specified target frame rate."
    • Motivation to Combine: A POSITA would combine these references to further optimize the system. Both Funkhouser and Funkhouser '93 (by the same author) aimed to enable complex virtual environments on low-cost workstations by reducing the processing burden. Applying the client-side optimization algorithm from Funkhouser '93 to the client-server system of Funkhouser was a complementary and logical step to manage client-side resources, a goal explicitly contemplated by Funkhouser itself.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Funkhouser and Marathon with Wexelblat (Patent 5,021,976) to teach avatar teleportation (Claim 17) and with Pratt (a 1993 technical paper) to teach switching between full and partial perspective views (Claim 19).

4. Key Claim Construction Positions

  • "avatar": Petitioner proposed this term be construed as "a graphical representation of a user," consistent with its use in the specification and its common meaning to a POSITA at the time.
  • "rendering": Petitioner proposed this term be construed as "a graphical image containing geometric models," based on the specification's description of a "graphical rendering engine" and the ordinary meaning in the field of computer graphics.
  • "third user perspective": As the term was not defined in the specification, Petitioner argued it could be interpreted as either the perspective of a remote user or a third-person "out of body" view. Petitioner contended the claims were obvious under either interpretation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-3, 7-8, and 11-20 of the ’998 patent as unpatentable.