PTAB

IPR2017-00005

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 web pages for multiple users. The system uses configurable applications, such as a biography application for an administrator and other applications based on user-generated content, and employs business rules to control how content is viewed and shared among users.

3. Grounds for Unpatentability

Ground 1: Claims 11-16, 18-23, 28-30 are obvious over Bezos

  • Prior Art Relied Upon: Bezos (Patent 7,433,832).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bezos, which describes features of the Amazon.com website, teaches every limitation of the challenged claims. Bezos discloses a system where users create personalized profile pages ("first configurable application") that function as biography applications for the profile owner ("administrator"). Bezos also teaches a "Personal Purchase Circle" feature ("second configurable application"), where users can selectively share purchase and review information with a defined group of other users. This second application is generated based on content from the administrator (their purchases) and other users (their purchases and reviews shared within the circle). The system uses configurable business rules to control content visibility, such as rules determining which purchases are shared (a "first business rule") and rules defining the membership of the purchase circle (a "second business rule"). Petitioner asserted that links on a user's profile to view "shared purchases" meet the "application link" limitation.
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference, which Petitioner asserted discloses all claimed elements. The motivation was simply to apply the known features described in Bezos in their intended manner. For any minor variations, Petitioner argued it would have been obvious to a person of ordinary skill in the art (POSITA) to implement Bezos's teachings in the claimed way, such as placing a hyperlink to a "Personal Purchase Circle" on a user's profile page to improve accessibility.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success as all components were known web technologies used for their intended purpose as disclosed in Bezos.

Ground 2: Claims 26 and 27 are obvious over Bezos in view of Rasansky and Barnett

  • Prior Art Relied Upon: Bezos (Patent 7,433,832), Rasansky (Patent 5,960,406), and Barnett (Patent 6,369,840).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that while Bezos teaches the base system of claim 15 (a communications application), it does not explicitly disclose an "events application that schedules and displays events" as required by dependent claim 26. Rasansky, which describes a web-based scheduling system ("Appointnet"), was asserted to cure this deficiency. Rasansky discloses an events application where an administrator can schedule events and where related communications (e.g., invitations) are automatically displayed in a user's inbox within the application. Claim 27's limitation of automatically transmitting communications to a selected group of users is also met by Rasansky, which describes sending automated email invitations for an event to invitees selected by the organizer.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the calendaring functions of Rasansky with the e-commerce and social sharing system of Bezos to enhance user engagement and drive sales. Petitioner cited Barnett, which expressly teaches that adding a web-based calendar to a merchant site (like the Amazon.com site in Bezos) provides powerful commercial benefits, such as reminding users of birthdays and providing opportunities to purchase gifts or other related items.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in combining these web-based technologies, as Rasansky's system was designed to work with standard web browsers and would predictably integrate with the website framework described in Bezos.

4. Key Claim Construction Positions

  • "application" / "configurable application": Petitioner proposed that "application" should be construed as "a unit of content on a network site." This broad construction was central to its argument, as it allowed features from Bezos like a user's profile page or a "Personal Purchase Circle" (which are collections of content and functionality) to be mapped onto the claim limitation of an "application." A "configurable application" was accordingly construed as an "application that can be modified or configured."
  • "biography application": Petitioner proposed the construction "an application that provides biographical information." This interpretation allowed a standard user profile page in Bezos, which displays the user's name, personal description, and other user-provided details, to satisfy the claim limitation for a "biography application."
  • "business rule": Petitioner proposed construing this term as "a rule incorporated into the system that controls how the system functions." This construction allowed the user-configurable privacy settings and group membership definitions in Bezos (e.g., designating a purchase as public or private, or defining members of a "Personal Purchase Circle") to be considered "business rules."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 11-16, 18-23, and 26-30 of the ’720 patent as unpatentable.