PTAB

IPR2015-01706

BITCO Corp v. Intellectual Ventures II LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: System and method for providing a centralized access point for distributed information.
  • Brief Description: The ’177 patent discloses a network-based system where a user can create a personalized "centralized access point," such as a custom web page. The system enables the user to select desired "content" from various "distributed information access points" and aggregates it on their personal page for convenient access.

3. Grounds for Unpatentability

Ground 1: Obviousness over MyLibrary - Claims 11, 12, and 16-20 are obvious over MyLibrary.

  • Prior Art Relied Upon: MyLibrary (a 1999 article by Eric Lease Morgan titled "MyLibrary: A Model for Implementing a User-centered, Customizable Interface to a Library's Collection of Information Resources").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that MyLibrary, a well-documented system for creating personalized library web portals, disclosed all major elements of the challenged claims. MyLibrary described a system where users could customize a personal web page by selecting links to various information resources (e.g., databases, electronic journals, articles) from pre-defined customization pages. Petitioner contended this system directly mapped to the claimed invention, where the user's personal MyLibrary page is the "centralized access point," and the customization pages are the "distributed information access points."
    • For independent claim 11, Petitioner asserted that MyLibrary’s server, which stores the user's selections and profile information, satisfied the claim’s server storage limitations (e.g., storing "links to content" and "information about users"). Petitioner also argued that MyLibrary’s described administrative menu, which allowed librarians to manage the resources available for user selection, met the "administrative interface ... operative to create groupings of content" limitation.
    • For independent claim 16, Petitioner argued that the method of a MyLibrary user selecting resources from customization pages for inclusion on their personal page directly taught the claimed step of "selecting content from one or more ... distributed information access points for addition to a centralized access point."
    • Motivation to Combine/Modify: Petitioner acknowledged that MyLibrary did not explicitly teach a user "log on" capability, a limitation present in the challenged claims (e.g., "capability to log on to their centralized access point"). However, Petitioner argued that modifying the MyLibrary system to include a user log-on would have been obvious to a person of ordinary skill in the art (POSITA) at the time. The motivation was clear and compelling: to provide secure, persistent, and personalized access for individual users, a standard and widely adopted practice for web-based portals and services.
    • Expectation of Success: A POSITA would have had a high expectation of success in adding a standard log-on function to the MyLibrary system. This modification involved applying well-known and routine programming techniques to a web-based system to achieve the predictable result of user authentication and session management.

4. Key Claim Construction Positions

  • "content": Petitioner argued that, under the broadest reasonable interpretation, the term "content" must be construed to include "links to content." The petition asserted that this construction is compelled by the patent's intrinsic evidence, which explicitly describes a "link type content object" and shows a link being used as a form of content in its figures. This construction was central to the invalidity case, as the primary prior art reference, MyLibrary, operates by adding links to a user's portal page. Petitioner argued that a narrow construction excluding links would be improper as it would read out the patent's own preferred embodiments.
  • "selecting content ... for addition to a centralized access point": Consistent with the construction of "content," Petitioner argued this claim phrase must cover the selection of an item that results in the addition of a link to the user's page. The petition pointed to the patent’s only detailed embodiment of this functionality (Figures 8-10), which illustrates that when a user "adds" content, what actually appears on their personal page is a link to that content. Therefore, Petitioner contended that any construction requiring the addition of the underlying content file itself, rather than a link to it, would be inconsistent with the specification's disclosure.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 11, 12, and 16-20 of the ’177 patent as unpatentable under 35 U.S.C. §103.