PTAB

IPR2016-01434

HCC Insurance Holdings Inc v. Intellectual Ventures I LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus for Distributing Content Objects to a Personalized Access Point of a User Over a Network-Based Environment and Method
  • Brief Description: The ’177 patent discloses a system to address internet "information overload" by providing a user with a personalized "centralized access point" (e.g., a personal web page). This centralized point aggregates and provides access to content selected by the user from various other network locations, termed "distributed information access points."

3. Grounds for Unpatentability

Ground 1: Claims 11-20 are obvious over Robinson in view of Bezos.

  • Prior Art Relied Upon: Robinson (a 1998 book titled Official Excite Internet Yellow Pages) and Bezos (Patent 6,963,840).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Robinson, which describes the Excite.com web portal of the late 1990s, teaches most limitations of the challenged claims. Robinson discloses a system with servers that provide users with a personalized home page ("centralized access point") accessible via a logon. Users can select and customize their page with content like news, stock quotes, and links to favorite websites, which are sourced from various web pages ("distributed information access points"). However, Petitioner contended Robinson does not explicitly teach an "administrative interface" for creating content groupings.
    • Motivation to Combine: To supply the missing element, Petitioner pointed to Bezos. Bezos discloses a web-based community system where a "system administrator" uses an "interface" to create and group content into "communities" that users can then add to their personalized pages. Petitioner argued a person of ordinary skill in the art (POSITA) would combine Bezos's administrative interface with the user-facing portal of Robinson. This combination represented a known solution for managing the large volume of content in a portal system like Excite, allowing administrators to organize content effectively.
    • Expectation of Success: A POSITA would have a high expectation of success, as both references describe functionally similar web-based portals for delivering personalized content, making the integration of a backend administrative tool a straightforward and predictable task.

Ground 2: Claims 13-15 are obvious over Robinson and Bezos in view of Coates.

  • Prior Art Relied Upon: Robinson (a 1998 book), Bezos (Patent 6,963,840), and Coates (a 1999 Chicago Tribune article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the base combination of Robinson and Bezos to specifically address claims requiring the system to "accept content contributions from a user" (claim 13) and "manage" that content (claims 14-15). Petitioner asserted that Coates, which describes the "TrueSynch" feature of the Excite portal, teaches this functionality. TrueSynch allowed users to synchronize personal data—such as calendar entries, address book contacts, and notepad notes—from their personal computer software (e.g., Microsoft Outlook) to their personalized Excite page. Petitioner framed this synchronization of user data as a "content contribution" accepted by the system.
    • Motivation to Combine: A POSITA would combine the teachings of Coates with the Robinson/Bezos system because all references describe features of the same commercial platform, Excite.com. Adding a synchronization feature would have been a natural evolution of the portal, making it more central to a user's digital life by integrating their personal information with web content. This would enhance the portal's value and accessibility.
    • Expectation of Success: Success would be reasonably expected because Robinson and Coates describe the same underlying system. Implementing a feature (TrueSynch from Coates) into the system it was designed for (Excite portal from Robinson) was a predictable integration.

Ground 3: Claims 13 and 15 are obvious over Robinson and Bezos in view of Excite Page.

  • Prior Art Relied Upon: Robinson (a 1998 book), Bezos (Patent 6,963,840), and Excite Page (an archived web page from Jan. 1999).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground also targets claims related to user content contributions and administrative management but relies on a different mechanism. Petitioner argued that Excite Page, an archived "Add Your Site to Excite's Database" page, discloses a method for users to contribute content. The page allowed a user to submit a URL, which Excite's "spider" would then crawl and index. Petitioner asserted that this submission and subsequent indexing constituted the system "accepting content contributions from a user." Excite administrators could then manage this user-contributed content by curating it for directories or including it in categorized databases.
    • Motivation to Combine: A POSITA would integrate the URL submission functionality of Excite Page into the Robinson/Bezos portal to improve the system's search engine. Allowing users to submit URLs would expand the corpus of indexed content, making the portal's search results more comprehensive and valuable for all users. The motivation was to leverage the user base to enhance a core feature of the portal.
    • Expectation of Success: A high likelihood of success was expected, as Robinson, Bezos, and Excite Page all relate to features of the same or similar web portal systems. Combining a front-end URL submission tool with a back-end administrative interface and a user-facing search engine was a well-understood architecture at the time.

4. Key Claim Construction Positions

  • "access to content": Petitioner argued this term should be construed broadly to include providing links to content, not just hosting or embedding the content itself. This construction was critical because the prior art portals, like Excite, functioned primarily by aggregating and displaying links.
  • "administrative interface": Proposed construction was "a software management tool that facilitates administrative functions." This construction supported the combination with Bezos, which explicitly taught an interface for system administrators to manage content groupings.
  • "centralized access point": Proposed as "a user's network resource that can be used to access content," aligning with the concept of a personalized homepage in the prior art.
  • Preambles of Claims 11 and 16: Petitioner argued the preambles are non-limiting because the claim body recites a complete apparatus and method, and no claim limitations rely on the preamble for antecedent basis.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 11-20 of Patent 7,516,177 as unpatentable.