PTAB

IPR2016-01519

DISH Network LLC v. Grecia William

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Digital Cloud Access (PDMAS Part III)
  • Brief Description: The ’308 patent discloses a process for transforming a user access request for cloud-based digital content into a computer-readable authorization object. The process involves a first authentication step using a "verification token" against a first database, followed by a second step of establishing an API communication with a "verified web service" to retrieve a web service account identifier, which is then used to create the final authorization object.

3. Grounds for Unpatentability

Ground 1: Obviousness over Tiu and Fetterman - Claim 1 is obvious over Tiu in view of Fetterman.

  • Prior Art Relied Upon: Tiu (Application # 2008/0222199) and Fetterman (Application # 2008/0313714).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the primary reference, Tiu, discloses the core framework of the challenged claim. Tiu describes a social network (Friendster) where users can link third-party content (e.g., from Flickr or YouTube) to their landing pages. This process involves a two-step authentication: (1) The user provides credentials (a "verification token") for the third-party site, which are authenticated against the third-party's database. (2) The user is then prompted for their social network credentials, which are sent via an API to the social network's database to authorize linking the content. This process results in the creation of an HTML EMBED code (the "authorization object") on the user's landing page, which contains the necessary information to retrieve the third-party content. Petitioner contended this system maps to the key steps of claim 1, including receiving an access request, authenticating a token against a first database, and then establishing an API communication with a different database to create an authorization object.

    • Motivation to Combine (for §103 grounds): Petitioner argued that Tiu discloses a system where the third-party server acts as an intermediary, receiving the user's social network credentials and forwarding them to the social network's API. Fetterman, which describes the Facebook API, teaches a simpler, more direct alternative where the user's device itself calls the social network's API directly from the browser to initiate the login process. A Person of Ordinary Skill in the Art (POSITA) would combine Fetterman’s well-known, simpler API login method with Tiu's overall framework to reduce programming complexity and create a more efficient system. This substitution was presented as a predictable design choice, combining known elements for their established functions.

    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in this combination because it involves substituting one known API login method (Tiu's indirect method) with another well-documented and functional API login method (Fetterman's direct method) to achieve the same predictable result of user authentication.

4. Key Claim Construction Positions

  • "verified web service": Petitioner argued for the construction "any web service that is used to authenticate the identity of a user or a device." This construction was supported by the patent's own example of using a Facebook login with a username and password to authenticate a user, rather than authenticating a credential itself.
  • "verification token": Petitioner proposed construing this term as "any data that can be used to verify identity or rights to content, such as identity of a user by verifying a username or other identifying information." This interpretation broadens the term beyond a simple alphanumeric code to encompass the username/password combinations disclosed in the prior art, which Petitioner argued was consistent with the specification's examples.
  • "authorization object": Petitioner argued this term, which is not defined in the specification, should be construed as "any data that includes at least one of the verification data... or an identifier for a verified web service... that indicates user access rights associated with the digital content." Under this construction, Petitioner mapped the term to the HTML EMBED code created in Tiu's system, which contains the necessary user authentication data to access the third-party content.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claim 1 of the ’308 patent as unpatentable under 35 U.S.C. §103.