PTAB

IPR2017-00004

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 web-based system for managing user-generated content. The system allows users to create profiles, utilize configurable applications (e.g., biography, events), and manage content visibility through an administrator portal using customizable business rules.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bezos and Weiss - Claims 1-3, 5-7, 9, and 10 are obvious over Bezos in view of Weiss.

  • Prior Art Relied Upon: Bezos (Patent 7,433,832) and Weiss (WO 01/063919).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bezos, which describes an e-commerce website with features similar to Amazon.com, discloses most limitations of the independent claims. Bezos teaches a system for managing content on a website where users have stored profiles. It discloses a "plurality of configurable applications" by mapping a user's profile page as a first "biography application" and the product review system as a second configurable application. Petitioner contended that Bezos’s user profile pages function as an "administrator portal" where users (acting as administrators of their own pages) can manage "business rules" to control content visibility, such as designating "trusted friends" who are permitted to view private information like shared purchases.
    • Motivation to Combine: Petitioner asserted that while Bezos teaches using standard text hyperlinks to a user's profile page, it does not expressly disclose that this link is "configurable." A Person of Ordinary Skill in the Art (POSITA) would combine Bezos's system with the hyperlink preview technology taught by Weiss. Weiss teaches generating a graphical thumbnail preview of a linked webpage. The motivation was to improve upon Bezos's simple text links by providing a dynamic, graphical preview of the user's profile page, thereby enhancing the user experience and allowing for a more informed decision before navigating to the page.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying a known web enhancement technique (Weiss) to a standard web-based system (Bezos), which was a predictable implementation.

Ground 2: Obviousness over Bezos, Weiss, Rasansky, and Barnett - Claims 4 and 8 are obvious over Bezos and Weiss, in further view of Rasansky and Barnett.

  • Prior Art Relied Upon: Bezos (Patent 7,433,832), Weiss (WO 01/063919), Rasansky (Patent 5,960,406), and Barnett (Patent 6,369,840).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses dependent claims 4 and 8, which add limitations requiring an "events application" and a "communications application." Petitioner argued that the combination of Bezos and Weiss, as established in Ground 1, lacks these specific application types. Rasansky was cited for its disclosure of a web-based calendaring system ("appoint.net") that schedules and displays events, meeting the "events application" limitation. Rasansky further discloses an integrated messaging system ("In Box") for sending and receiving messages related to calendar events, thereby teaching a "communications application."
    • Motivation to Combine: A POSITA would combine the teachings of Rasansky with the Bezos/Weiss system to add valuable functionality. Petitioner cited Barnett for providing an explicit commercial motivation. Barnett teaches that adding an online calendar to an e-commerce website can drive sales by providing opportunities for users to purchase items related to scheduled events (e.g., buying gifts for birthdays). This direct financial incentive, coupled with the analogous nature of the web-based technologies, provided a strong motivation to integrate Rasansky's calendaring and communication features into the Bezos e-commerce platform.
    • Expectation of Success: The integration was argued to be predictable and straightforward, as Rasansky's system was designed to operate using standard web technologies and would not have presented any significant technical obstacles when combined with the Bezos system.

4. Key Claim Construction Positions

  • "application" / "configurable application": Petitioner proposed a broad construction of "application" as a "unit of content on a network site." A "configurable application" is therefore an "application that can be modified or configured." This broad interpretation was central to Petitioner's argument that a user's profile page and a product review system, as taught in Bezos, qualify as distinct "configurable applications" under the claims.
  • "link" / "configurable link" / "application link": Petitioner argued a "link" is a "mechanism to activate an application on a network site." A "configurable link" or "application link" is a link that can be modified as permitted by business rules. This construction supports the argument that combining Bezos's text link with Weiss's preview technology results in a link whose appearance (the preview image) is configured based on the content of the target profile page.
  • "administrator portal" and "business rule": Petitioner proposed construing "administrator portal" as an "interface for managing applications and/or business rules" and "business rule" as a "rule incorporated into the system that controls how the system functions." These constructions were used to argue that a standard user managing privacy settings for their own profile page in Bezos (e.g., setting "trusted friends") is acting as an "administrator" using a "portal" to manage "business rules."

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-10 of Patent 9,141,720 as unpatentable.