PTAB

IPR2016-00273

Plaid Technologies Inc v. Yodlee Inc

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Key Events
Petition
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1. Case Identification

2. Patent Overview

  • Title: Apparatus and Process for Automated Aggregation and Delivery of Electronic Personal Information
  • Brief Description: The ’783 patent discloses a system for automatically aggregating and delivering a user’s personal information from a plurality of remote, online information providers. The system uses a central processor to connect to providers, retrieve user data using stored credentials, and present the aggregated information to the end user.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-20, and 22-36 are obvious over Sugiarto in view of Brandt.

  • Prior Art Relied Upon: Sugiarto (Patent 6,278,449) and Brandt (Patent 5,892,905).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sugiarto disclosed a system for aggregating information from various public web pages (e.g., CNN, ESPN) based on a user's configuration file and presenting it on a single, customized web page. However, Sugiarto focused on public data. Petitioner contended that Brandt remedied this deficiency by teaching an "Internet gateway" that automatically authenticates a user to access multiple, different secure software applications using stored user credentials. The petition asserted that combining these references would result in Sugiarto’s aggregation system being enhanced with Brandt’s automatic authentication capability. In the combined system, Sugiarto’s content gathering modules would be modified to automatically log into secure websites to retrieve "non-public" personal information, in addition to the public information it already gathered.
    • Motivation to Combine: The petition asserted that by the ’783 patent’s priority date, there was a recognized need for aggregating both public data and the growing amount of private, password-protected data available online (e.g., financial accounts, subscription services). A person of ordinary skill in the art (POSITA) would combine Sugiarto’s public aggregation framework with Brandt’s automated authentication technology to create a more comprehensive and commercially valuable service. This combination would predictably improve the user experience by eliminating the need to manually log in to multiple sites.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because automated authentication was a well-understood technology. Brandt's gateway functionality could be incorporated into Sugiarto's content-gathering modules without significant architectural changes, as both systems were invoked via standard HTTP requests. The petition further detailed that using APIs to interact with secure sites, as taught by Brandt, was a straightforward implementation method.

Ground 2: Claims 2 and 21 are obvious over Sugiarto in view of Brandt, in further view of Chow.

  • Prior Art Relied Upon: Sugiarto (Patent 6,278,449), Brandt (Patent 5,892,905), and Chow (Patent 6,029,175).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed the additional limitations of claims 2 and 21, which required "monitoring information providers for changes." Petitioner asserted that the base combination of Sugiarto and Brandt failed to expressly teach this feature. Chow, however, explicitly disclosed a "Revision Manager," a software agent designed to solve the problem of web servers being "stateless" by spontaneously monitoring a server to detect if a document had been modified. Petitioner argued that adding Chow’s Revision Manager to the Sugiarto/Brandt combination directly taught the claimed monitoring functionality.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Chow's monitoring capability into the combined Sugiarto/Brandt system to ensure the aggregated personal information remained current. Without such monitoring, the aggregated data would become stale, diminishing the system's utility. Chow provided a known solution to a known problem (stale data) that would have been a natural and desirable improvement to an information aggregation service.
    • Expectation of Success: The petition contended that integrating Chow’s technology would be straightforward. Chow’s Revision Manager was designed as a software agent that could be implemented without requiring significant changes to existing web client or server technology. Therefore, a POSITA could have incorporated it into the Sugiarto/Brandt system with a high degree of confidence.

4. Key Claim Construction Positions

  • "non-public": Petitioner argued this term, which was added during prosecution to overcome prior art, should be construed to mean information on websites that is not accessible to the general public and requires a user to log in (e.g., with a username and password). This construction was critical for establishing the relevance of Brandt, which teaches a system for automating such logins.
  • "intermediary web site": For claims 14 and 33, Petitioner proposed that the broadest reasonable construction is a website served by a web server that is not running on the end user's computer and is also not the central "processor" of the claimed system. This interpretation supported mapping Sugiarto's disclosure of delivering customized web pages to this limitation.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-36 of the ’783 patent as unpatentable.