PTAB

IPR2015-01372

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 ’279 patent discloses a system for providing message notifications to a user’s computer. The system uses a central server to receive data from information sources, process it into data blocks, and transmit it over a wireless broadcast network (e.g., a pager network) to a receiver connected to the computer, enabling notifications even when the computer is offline from a different data connection like the Internet.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hays, Pepe, and Throckmorton - Claims 8, 10, 13-16, 20-23, 25, 26, 28, 30-32, 42, 44, 47-52, 54-57, 59, 60, 62, 64-66 are obvious over Hays in view of Pepe and 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: Petitioner argued that Hays alone discloses the core elements of independent claims 1 and 35. Hays describes a telecommunication system where a central server (comprising a "message manager" and a Universal Messaging System) receives data from various information sources (e.g., callers, stock market services). This server processes the data by checking validity and destination, then broadcasts a page message to a mobile unit's pager. Crucially, this transmission occurs whether the mobile unit's cellular phone component is online or offline, thus teaching the key online/offline notification feature. The server components in Hays perform the functions of the claimed central broadcast server, information gateway, and transmission gateway.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the contemporaneous and technologically similar systems of Hays and Pepe to integrate Pepe’s more detailed implementation of a subscriber database for message protocol and address translation. This combination would improve Hays’s system in a predictable manner. A POSITA would further incorporate Throckmorton’s teachings on using Uniform Resource Locators (URLs) and commands within messages. This would enhance the combined Hays/Pepe system by allowing users to retrieve additional information referenced in a notification, a known technique for making broadcast data interactive.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining these known elements involved applying conventional technologies (subscriber databases, URLs) to similar messaging systems for their intended and well-understood purposes.

Ground 2: Obviousness over Kane and Throckmorton - Claims 5, 10, 14-16, 18, 20, 21, 23, 25, 26, 28, 31, 32, 44, 48-50, 52, 54-57, 59, 60, 65, and 66 are obvious over Kane in view of Throckmorton.

  • Prior Art Relied Upon: Kane (Patent 5,487,100) and Throckmorton (Patent 5,818,441).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Kane discloses a system for transmitting information to a user’s computer via two distinct channels: a wireless paging network (“Path B”) and a separate dial-up Internet connection (“Path A”). Kane’s central terminal receives information from sources like an X.400 email network, processes the messages by parsing them and converting email addresses to pager numbers via a subscriber database, and then transmits them as pager messages over Path B. This transmission occurs regardless of whether the remote device’s dial-up modem is online or offline, thereby teaching the core invention. Kane’s central terminal and its controller software map to the claimed central broadcast server and information/transmission gateways.
    • Motivation to Combine: A POSITA would combine Kane and Throckmorton because they address similar problems of providing information to a remote client over multiple communication paths and both contemplate sending a shorter message with a method to obtain more information. The motivation was to incorporate Throckmorton’s teachings on using URLs and embedded commands into Kane’s notification messages. This would predictably enhance Kane’s system by making the notifications interactive and allowing users to easily retrieve detailed information from a secondary source.
    • Expectation of Success: A POSITA would have reasonably expected success in adding URL functionality from Throckmorton to Kane's messaging system, as it was a straightforward application of a known web technology to an existing notification framework.

4. Key Claim Construction Positions

  • Petitioner argued that the claims were unpatentable even under the Patent Owner’s own proposed claim constructions, which were broader than Petitioner’s. For the key terms “information gateway” and “transmission gateway,” Petitioner adopted SimpleAir’s proposed constructions for the purpose of the petition.
  • "information gateway": Construed as “one or more software programs…that build data blocks and assign addresses to said data blocks.” Petitioner argued this broad definition was met by software functions in Hays’s message manager and Kane’s central terminal controller.
  • "transmission gateway": Construed as “one or more software programs…that prepare the data blocks for their transmission to receivers and interface with other resources used to transmit the preprocessed data.” Petitioner argued this was met by the Universal Message System in Hays and the paging encoder in Kane.
  • Significance: By demonstrating obviousness under the Patent Owner’s broader, non-means-plus-function constructions, Petitioner aimed to show the claims were invalid regardless of disputes over claim scope.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 5, 8, 10, 13-16, 18, 20-23, 25, 26, 28, 30-32, 35, 42, 44, 47-52, 54-57, 59, 60, 62, and 64-66 of Patent 8,572,279 as unpatentable under 35 U.S.C. §103.