PTAB

IPR2016-00717

WhatsApp Inc v. TriPlay Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Messaging System and Method
  • Brief Description: The ’677 patent describes a messaging system and method for adapting an initial message sent from an originating device for delivery to a destination device. The system adapts the message's format and/or layout based on criteria related to the destination device's capabilities, such as display size, and in some embodiments, uses a template-based system to manage message layouts.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 11, 13, 14, 16, 17, 20, and 21 are obvious over Coulombe in view of Bellordre and Friedman.

  • Prior Art Relied Upon: Coulombe (Application # 2003/0236892), Bellordre (Application # 2006/0176902), and Friedman (Patent 7,593,991).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Coulombe, discloses a messaging system that performs the core steps of the independent claims: receiving a message, obtaining the destination device's capabilities, and converting the message's format and layout to conform to those capabilities before delivery. Bellordre was cited for the unremarkable teaching that a multimedia message can include a video object, which can be processed and adapted (e.g., modifying its size). Friedman was cited to teach generating a clickable thumbnail graphic based on a video attachment, where clicking the thumbnail opens the video. The combination of these references, Petitioner asserted, discloses every limitation of the independent claims, including converting a video message and providing a clickable icon for an adapted version of that video. Dependent claims were mapped to specific teachings within these references, such as transcoding (Coulombe) and adapting the icon itself (obvious over Coulombe and Friedman).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Coulombe with Bellordre because they are analogous references addressing the same problem of adapting messages for mobile terminals, and adding video capability was a self-evident and desirable improvement. A POSITA would have been motivated to incorporate Friedman's clickable thumbnail generation into the Coulombe/Bellordre system to provide a user-friendly and straightforward method for accessing video attachments, an established advantage in user interface design.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination, as it involved applying known messaging features (video content, clickable thumbnails) to a known adaptation system for their conventional purposes, resulting in a predictable improvement.

Ground 2: Claims 3, 5, 12, and 19 are obvious over Coulombe, Bellordre, and Friedman, and further in view of Meyer and Ito.

  • Prior Art Relied Upon: The combination from Ground 1, plus Meyer (Cascading Style Sheets: The Definitive Guide, 2d ed. 2004) and Ito (Application # 2003/0084405).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claims requiring the message layout to be based on a "template" characterized by a "unique template identifier." Petitioner argued that an HTML document constitutes a "message" and that, per Meyer, an external Cascading Style Sheet (CSS) file functions as a "template" that defines the layout of an HTML document. Meyer further taught that such an external style sheet is identified and linked by a unique identifier, a URL. Ito was cited for its teaching of a system that selects an appropriate style sheet to apply to a document by using an embedded URI as a key to search a database of style sheets. This combination, Petitioner contended, taught providing an adapted message layout in accordance with the unique template identifier (the URL).
    • Motivation to Combine: A POSITA would combine Meyer and Ito with the base combination from Ground 1 to implement the message layout adaptation using well-known, powerful, and efficient CSS techniques. Meyer explained the advantages of centralizing style information for consistency across multiple documents. A POSITA would be motivated to apply Ito's method of dynamically selecting style sheets to make the Coulombe system more flexible, allowing it to adapt layouts by referencing different centrally-stored templates based on the message identifier and recipient device capabilities.
    • Expectation of Success: The use of CSS to control document presentation was a fundamental and widespread technique, ensuring a high expectation of success in applying these methods to adapt message layouts.

Ground 3: Claims 4 and 18 are obvious over Coulombe, Bellordre, Friedman, Meyer, and Ito, and further in view of Surana.

  • Prior Art Relied Upon: The combination from Ground 2, plus Surana (Application # 2006/0069790).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claims requiring the association of the unique template identifier with one or more "predefined adapted message layouts" and selecting a layout based on the identifier and device criteria. Surana was cited for teaching a system that adapts content presentation by replacing an original style sheet in an HTML document with a new one selected from a set of predefined, stored style sheets. Surana taught using a "look-up table" to select the appropriate replacement style sheet based on criteria such as the properties of the HTML file and the capabilities of the destination terminal (e.g., display size).
    • Motivation to Combine: A POSITA would have been motivated to incorporate Surana’s teachings to enhance the template-based system of Ground 2. Surana provided an explicit method for creating a more sophisticated adaptation system where a single template identifier in an incoming message could be used as a key to select from multiple predefined layouts, choosing the one best suited for the specific destination device. This provided a more robust and scalable solution to message adaptation.
    • Expectation of Success: Combining Surana’s look-up table selection method with the CSS template system of Meyer and Ito was a straightforward application of known data retrieval and content adaptation techniques that would have predictably resulted in a more versatile messaging system.

4. Key Claim Construction Positions

  • "Message": Petitioner proposed the construction "any kind of communication object capable of being exchanged between communication devices," based on the patent's specification. This broad construction supports the argument that an HTML document qualifies as a "message."
  • "Template": Petitioner proposed the construction "any kind of predefined user interface related to content and/or layout of transmitted and/or received message." This construction was argued to be broad enough to encompass an external CSS file, which is a predefined user interface that dictates the layout of a message (i.e., an HTML document).

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-5, 11-14, and 16-21 of Patent 8,874,677 as unpatentable.