PTAB

IPR2017-00886

RPX Corp v. Link Engine Technologies LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Web Playlist System, Method, And Computer Program
  • Brief Description: The ’694 patent discloses systems and methods for displaying a sequence of web pages in a browser, akin to a slideshow. The technology involves a "playlist engine" that retrieves network addresses from a list, a control panel for user interaction (e.g., play/pause), and a timer to display the time remaining for each page.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 7-10, 13-17, and 20-31 are obvious over Quimby

  • Prior Art Relied Upon: Quimby (Application # 2002/0199002).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Quimby, which discloses a "web site access system" for viewing a "slide show" of web pages, teaches all limitations of the independent claims. Quimby's "performer" software was asserted to be the claimed "playlist engine" that retrieves a list of URLs and displays them in sequence. Petitioner contended that Quimby’s control panel with "site-forward" and "site-backward" buttons, along with pause/resume functions, met the "control panel" limitation. The petition further argued that Quimby’s "time remaining field" met the "timer" limitation, and its interface for setting a "default duration" for pages met the "duration values" limitation. For claims directed to a "data file" (e.g., claim 13), Petitioner asserted that an HTML/JavaScript file generated by Quimby's server-side code (jsperformer.asp) satisfied this limitation.
    • Motivation to Combine (for §103 grounds): This ground relies on a single reference. However, for the data file claims, Petitioner argued a person of ordinary skill in the art (POSITA) would be motivated to make minor modifications for portability and ease of debugging, such as consolidating referenced JavaScript files into a single HTML file.
    • Expectation of Success (for §103 grounds): Petitioner asserted success would be predictable, as combining JavaScript code into a single HTML file was a common and well-understood practice.

Ground 2: Claims 5, 11, 18, and 32 are obvious over Quimby in view of Lenz

  • Prior Art Relied Upon: Quimby (Application # 2002/0199002) and Lenz (WO 98/20434).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses the dependent claims requiring "preloading," i.e., retrieving a subsequent web page in a sequence while the current page is being displayed. Petitioner argued that while Quimby provided the base slideshow system, it did not explicitly disclose preloading. Lenz was introduced because it expressly teaches a "preload function" where a "preload module" fetches web pages with the "highest priority" to reduce delay and improve user experience.
    • Motivation to Combine (for §103 grounds): Petitioner asserted a POSITA seeking to improve the performance of Quimby's web slideshow would be motivated to incorporate Lenz's known technique for preloading. Both references shared the common goal of presenting sequences of web pages, and Lenz offered a well-documented solution to the known problem of latency between pages.
    • Expectation of Success (for §103 grounds): Success would be expected because preloading was a known technique for reducing wait times, and its application to Quimby's system would have produced the predictable result of a faster, more responsive slideshow.

Ground 3: Claims 6, 12, 19, and 33 are obvious over Quimby in view of Maddalozzo

  • Prior Art Relied Upon: Quimby (Application # 2002/0199002) and Maddalozzo (Patent 6,460,060).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targets claims requiring the display of web pages in "respective browser windows," or a multi-window display. Petitioner argued that Quimby taught a single-window slideshow. Maddalozzo was cited for its disclosure that browsers in the relevant time period conventionally allowed for multiple simultaneous windows and could open pages from a bookmark list into separate, independent windows.
    • Motivation to Combine (for §103 grounds): A POSITA implementing Quimby's system would be motivated to use Maddalozzo's conventional multi-window approach for at least two benefits: allowing users to compare slides side-by-side and enabling users to easily switch back to a previously viewed slide without navigating backward and reloading. This combination was presented as a simple substitution of one known design element (multi-window display) for another (single-window display).
    • Expectation of Success (for §103 grounds): The result of the combination was argued to be predictable, as JavaScript commands for opening new browser windows (e.g., window.open) were well-known to a POSITA.

  • Additional Grounds: Petitioner asserted seven additional obviousness challenges, including combinations based on Lenz as the primary reference (e.g., Lenz alone, Lenz and Barrett, Lenz and Maddalozzo) and further combinations with Quimby (e.g., Quimby and Barrett). These grounds relied on similar arguments, mapping the base slideshow features to Lenz and introducing secondary references for preloading, multi-window displays, and single-file data structures.

4. Key Claim Construction Positions

  • "A Data File" (Claims 13-27): Petitioner proposed this term be construed as "one or more related data files." This construction was argued to be critical for mapping Quimby, which generates a primary HTML/JavaScript file that references an external .js file. Petitioner contended that even if a single file were required, it would have been obvious to combine Quimby's multiple files into one.
  • "Header section" (Claims 14-16, 21-23): Petitioner proposed this term be construed as "a section of a machine-readable data file that stores information about data that appears later in the file." This interpretation was used to argue that the <HEAD> portion of an HTML file, as generated by Quimby, met the claim limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-33 of the ’694 patent as unpatentable.