HCC Insurance Holdings, Inc. v. Intellectual Ventures I LLC

1. Case Identification

• Case #: IPR2016-01434
• Patent #: 7,516,177
• Filed: July 14, 2016
• Petitioner(s): Oracle America Inc., Oracle Corporation, HCC Insurance Holdings, Inc.
• Patent Owner(s): Intellectual Ventures II LLC
• Challenged Claims: 11-20

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 relates to systems for aggregating, enhancing, and distributing content objects to a user’s personalized network access point, such as a personal web page. The technology aims to solve the problem of "information overload" by allowing users to select and organize content from various distributed network locations into a single, centralized view.

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, discloses most elements of the challenged claims. Robinson taught a “centralized access point” in the form of a user’s personalized home page, which could be customized with content from various “distributed information access points” like news channels, stock tickers, and search results. Robinson also disclosed servers for storing content and user information, and a logon mechanism for accessing the personalized page. Petitioner contended that the primary element not explicitly detailed in Robinson is the "administrative interface... operative to create groupings of content" recited in independent claim 11. To supply this element, Petitioner turned to Bezos, which disclosed a system where administrators use an interface to create and define communities and content groupings for users.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Robinson and Bezos to provide the administrators of the Excite system (disclosed in Robinson) with a more effective tool for organizing and grouping the vast amounts of available content. Bezos provided a readily available, known solution for managing content groupings in a web-based system, and applying its teachings to Robinson's system would have been a common-sense improvement to enhance content organization.
  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because both references describe web-based content management systems, and implementing the administrative interface from Bezos into the server-based architecture of Robinson would involve known programming techniques.

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

• Prior Art Relied Upon: Robinson, Bezos, and Coates (a 1999 Chicago Tribune article describing Excite.com).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Robinson and Bezos and added Coates to further support limitations in dependent claims 13-15. Claim 13 requires the distributed information access point to "accept content contributions from a user." Petitioner argued Coates taught this by describing a feature called "TrueSynch" for the Excite portal, which allowed users to synchronize content (calendar, address book, notepad notes) from their local computer to their personalized Excite page. This synchronization was argued to be a form of "content contribution." For claim 14 (managing contributed content) and claim 15 (administrative interface managing contributed content), Petitioner argued that the notepad feature in Robinson, combined with the synchronization taught by Coates, would render it obvious to manage this synced content.
  • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate the synchronization feature from Coates into the Robinson system because both references describe the same Excite platform. Combining these features would make user-specific content more accessible and centralized, which was a key goal of such web portals. It was a logical extension to allow users to contribute and manage their own information (from Coates) within the personalized portal framework (from Robinson).
  • Expectation of Success (for §103 grounds): Success was expected because Robinson and Coates describe features for the same underlying system (Excite), making their integration straightforward.

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

• Prior Art Relied Upon: Robinson, Bezos, and Excite Page (an archived Excite.com webpage from January 1999).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground provided an alternative basis for the obviousness of claims 13 and 15. It used the Excite Page reference to show a different method for accepting "content contributions from a user" (claim 13). The Excite Page disclosed a function allowing a user to submit a URL of their own website to Excite's database. Excite's "spider" would then crawl and index the submitted page, making it part of Excite's searchable content. Petitioner argued this submission and indexing process constituted "accepting" a content contribution. For claim 15, Petitioner argued it would have been obvious for Excite's administrators (editors) to use their administrative interface to manage these user-contributed websites, for instance, by curating them into a directory.
  • Motivation to Combine (for §103 grounds): The motivation was to combine known functionalities of the Excite system to enhance its search database. Allowing users to submit URLs (from Excite Page) and having administrators manage that content (an obvious extension of their role in Robinson) would improve the breadth and quality of the portal's indexed content.
  • Expectation of Success (for §103 grounds): A POSITA would expect success as the Excite Page and Robinson both describe the same Excite system, and screenshots in Robinson even show links to the "Add URL" functionality described in the Excite Page reference, demonstrating the features were already integrated.

4. Key Claim Construction Positions

• "administrative interface" (Claim 11, 15): Petitioner proposed the construction "a software management tool that facilitates administrative functions." This was argued to encompass software tools used by administrators or editors to manage content, such as by indexing websites, creating directories, or moderating message boards.
• "distributed information access point" (Claims 11-13, 16, 19): Petitioner proposed "a network resource which is delivered to one or more users and that enables a user to interact with a centralized access point." This construction was argued to align with a prior court order and cover network resources like web pages or portions of web pages from which users could select content.
• "centralized access point" (Claims 11, 14, 16): Petitioner proposed "a user's network resource that can be used to access content," such as a personalized homepage. This construction, also based on a prior court order, emphasized that the point provides access to content (e.g., via links) and need not store the content itself.
• "access to content": Petitioner argued, based on prior PTAB decisions involving the ’177 patent, that this term is broad enough to be met by the presence of links to content and does not require the content to be hosted directly on the access point.

5. Relief Requested

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