PTAB

IPR2017-00003

Facebook, Inc. v. Zak, Bruce

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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 displayed on web pages for multiple users. The system uses user profiles, a plurality of configurable applications, and business rules to control how content is generated, displayed, and accessed by different users, including an administrator.

3. Grounds for Unpatentability

Ground 1: Claims 11-30 are obvious over Boyce in view of Parker.

  • Prior Art Relied Upon: Boyce (Excerpts from Microsoft Outlook Version 2002 Inside Out, 2001) and Parker (Patent 5,729,734).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Boyce and Parker renders the challenged claims obvious under 35 U.S.C. §103. The core of the argument focused on independent claim 11.
      • Boyce was asserted to teach a system for managing content that meets most limitations of claim 11. Specifically, Boyce describes the Microsoft Outlook/Exchange system with Outlook Web Access (OWA), which functions as a web-based system for managing content like emails, calendars, and contacts. Petitioner contended that OWA’s web pages for Inbox, Calendar, and Contacts are the claimed “plurality of configurable applications.”
      • The role of the “administrator” was mapped to the mailbox owner in Boyce, who can manage access for other users (“delegates”). The user profiles stored on the system were mapped to the user account information stored in Active Directory.
      • The claimed “biography application” (limitation [b]) was mapped to the OWA Contacts page, which displays biographical information. The claimed “application link” (limitation [d]) was mapped to the clickable icons in the OWA interface (e.g., "Inbox," "Calendar" icons) that allow users to navigate between applications.
      • The “business rules” (limitations [e] and [f]) were mapped to Boyce’s delegation settings. For example, a “first business rule” that determines content viewability corresponds to the setting that controls whether a delegate can see items marked as “private.” A “second business rule” that determines who can provide content corresponds to settings that grant a delegate “Editor” privileges, allowing them to create items in the administrator's mailbox.
      • Parker was introduced to supplement Boyce’s teaching of the “application link.” While Boyce teaches icons that function as links, Parker discloses user interface techniques for visually modifying the appearance of an icon (e.g., graying it out, displaying a lock) to indicate a user's specific access privileges for that item. Petitioner argued it would have been obvious to apply Parker’s visual cues to the clickable icons in Boyce's OWA system.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Parker’s UI techniques with Boyce’s OWA system to provide a clear and intuitive visual indication of a user’s access rights. This combination would improve the user experience by allowing a delegate to see the extent of their permitted access (e.g., read-only, no access) before attempting to click on an application link, thus streamlining navigation and preventing attempts to perform unpermitted actions.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because both references operate in the same field of networked folder access and employ similar permission-granting interfaces, making the application of Parker’s visual indicators to Boyce’s functional icons a predictable design improvement.

4. Key Claim Construction Positions

  • “application” / “configurable application”: Petitioner argued for a broad construction of “application” as a “unit of content on a network site,” not necessarily requiring an executable software program. This construction was central to mapping the OWA web pages for Inbox and Calendar—which are primarily content displays—to the claimed “applications.” Similarly, a “configurable application” was construed as an application that can be modified or configured, which Petitioner argued was met by the ability of a mailbox owner to set delegate permissions for these OWA pages.
  • “application link”: Petitioner proposed that “application link” should be construed as a “link that can be modified or configured as permitted by any relevant business rules.” This construction, broader than just a static URL, was critical for arguing that the clickable OWA icons, whose visibility or function could be altered by delegation rules (the “business rules”), met the claim limitation. It also created the nexus for introducing Parker’s teachings on visually modifying icons based on permissions.
  • “biography application”: Petitioner argued this term means an “application that provides biographical information,” without the limitation that it must be about people “involved in the organization sponsoring the web site.” This broader construction allowed the OWA Contacts page, which holds information for any contact, to be mapped to the claim limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 11-30 of the ’720 patent as unpatentable.