PTAB

IPR2017-00003

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 computer system for managing content on web pages for multiple users. The system uses stored user profiles and administrator-configurable business rules to control how users view and interact with various "configurable applications" accessible via the web pages.

3. Grounds for Unpatentability

Ground 1: Claims 11-30 are obvious over Boyce in view of Parker under 35 U.S.C. §103.

  • Prior Art Relied Upon: Boyce (a 2001 publication, "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 details the Microsoft Outlook/Exchange system and its Outlook Web Access (OWA) feature, discloses nearly all elements of the challenged claims. Boyce was presented as teaching a system for managing content (email, calendars, contacts) on web pages for multiple users with stored profiles. The mailbox owner acts as the "administrator," who can configure "delegation" permissions for other users. Petitioner mapped OWA's web-based inbox, calendar, and contacts pages to the claimed "plurality of configurable applications." The clickable icons in the OWA interface used to navigate between these applications were identified as the "application links." The "delegation" settings, which control what a delegate can see or do (e.g., view private items, edit content), were mapped to the claimed "business rules." For example, the setting allowing a delegate to see items marked "private" corresponds to the "first business rule," and the setting defining a delegate's access level (e.g., "Editor") corresponds to the "second business rule."

    • Motivation to Combine (for §103 grounds): Petitioner contended that while Boyce teaches configurable access, it does not explicitly disclose visually modifying the "application links" (icons) based on a delegate's permissions. To supply this element, Petitioner turned to Parker, which teaches user interface techniques for visually indicating a user's access privileges to shared network items (e.g., folders). Parker discloses graying out, hiding, or adding icons (like a lock or eyeglasses) to an item to show if a user has no access, read-only access, or write access. Petitioner argued a person of ordinary skill in the art (POSITA) would be motivated to combine Parker's intuitive UI feedback mechanism with Boyce's OWA system. The motivation was to improve usability by providing delegates with a clear, immediate visual cue about their access rights to different folders (e.g., Inbox, Calendar), preventing them from attempting actions they are not permitted to perform.

    • Expectation of Success (for §103 grounds): Petitioner asserted that a POSITA would have a reasonable expectation of success because the combination involved applying a known UI design principle (from Parker) to a standard networked application environment (from Boyce). The result—a web interface where icons are displayed differently based on user permissions—was argued to be a predictable outcome of this combination.

4. Key Claim Construction Positions

  • "application" / "configurable application": Petitioner proposed the construction "a unit of content on a network site" that can be modified or configured. This broad construction allowed Petitioner to argue that OWA's various content pages (inbox, calendar, contacts) qualify as the claimed applications.
  • "application link": Proposed as a "mechanism to activate an application on a network site" that can be modified or configured. This was critical for the obviousness argument, allowing Petitioner to identify the clickable navigation icons in OWA as the "links" and then argue for their modification based on the teachings of Parker.
  • "profile information": Construed as "information comprising attributes relating to a user of the system." This construction supported mapping Boyce's user account details and delegation settings to the claimed user profiles.
  • "business rule": Construed as a "rule incorporated into the system that controls how the system functions." This allowed Petitioner to equate Boyce's specific, user-configurable delegation settings with the patent's more generically claimed "business rules."

5. Relief Requested

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