PTAB

IPR2017-00002

Facebook Inc v. Zak Bruce

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Managing Content on a Network Interface
  • Brief Description: The ’720 patent describes a system for managing content on a web interface where different users can view and interact with configurable applications based on their user profiles and associated business rules. The system uses configurable links to provide access to content, which can be modified based on user-specific permissions.

3. Grounds for Unpatentability

Ground 1: Claims 1-10 and 31 are obvious over Boyce in view of Parker.

  • Prior Art Relied Upon: Boyce (a 2001 book titled "Microsoft Outlook Version 2002 Inside Out") and Parker (Patent 5,729,734).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Boyce, which detailed Microsoft’s Outlook Web Access (OWA) system, disclosed the core elements of the challenged claims. Boyce taught a web-based system for managing content (email, calendars, contacts) where users have profiles (account information) stored on an Exchange Server. OWA provided configurable applications, such as a user's inbox, calendar, and contacts pages, accessible via a web browser. The clickable icons in the OWA interface (e.g., "Inbox," "Calendar") functioned as the claimed "links."

    Petitioner asserted that Boyce’s "delegation" feature met the limitations for an "administrator portal" and user-configured business rules. This feature allowed a user (acting as an administrator) to grant other users ("delegates") varying levels of access to their own content. These delegation settings, such as whether a delegate has "Folder Visible" privileges or can see "private items," were presented as the claimed business rules that utilize user profiles to control access to the configurable applications.

    The petition contended that while Boyce taught configuring access permissions, Parker was introduced to render obvious the specific limitation of a visually modified configurable link. Parker disclosed user interface techniques for visually indicating a user’s access privileges for network folders, such as displaying an icon as grayed-out, ghosted, or with a lock symbol if access is restricted. Petitioner mapped this teaching to the clickable icons in Boyce's OWA interface, arguing it would have been obvious to apply Parker's visual cues to them. Dependent claims were addressed by mapping features also disclosed in Boyce, such as the calendar functioning as an "events application" and the inbox as a "communications application."

    • Motivation to Combine (for §103 grounds): A POSITA would combine Parker’s user interface techniques with Boyce’s OWA system to provide a clear, intuitive visual indication of a delegate's access permissions. Parker itself stated it is desirable for a user to be able to distinguish accessible items via indicating icons. This combination would improve the user experience in Boyce by preventing delegates from attempting to access content or perform actions for which they lacked permission, a predictable improvement for a known issue in systems with permission-based access.

    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because applying Parker’s well-understood visual indicators for access rights to the folder-based icon system in Boyce was a straightforward application of a known user interface principle to a similar system, with no technical barriers.

4. Key Claim Construction Positions

  • "profile information," "profile," and "user profile": Petitioner proposed the construction "information comprising attributes relating to a user of the system." This broad construction was argued to be consistent with the specification and encompassed the user account information, including delegate permissions, disclosed in Boyce.

  • "application" and "configurable application": Petitioner argued for "a unit of content on a network site" for "application," and an "application that can be modified or configured" for "configurable application." This construction allowed the OWA web pages for inbox, calendar, and contacts in Boyce to qualify as the claimed applications, as users could modify their content and administrators could configure access permissions for them.

  • "link," "configurable link," and "application link": Petitioner proposed "a mechanism to activate an application on a network site" for "link," and argued "configurable link" and "application link" should be construed as a "link that can be modified or configured as permitted by any relevant business rules." This construction was crucial for mapping the clickable icons in OWA, whose visibility to a delegate could be configured based on the "Folder Visible" permission (a business rule).

  • "administrator portal": Petitioner proposed the construction "interface for managing applications and/or business rules of the system." This allowed the delegation settings dialog boxes in Microsoft Outlook, as described by Boyce, to be considered the claimed administrator portal, as they were used to manage access rules for the OWA applications.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-10 and 31 as unpatentable.