PTAB

IPR2017-01652

Google Inc v. Spring Ventures Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: WWW Page Retrieval
  • Brief Description: The ’094 patent describes a method for retrieving a webpage by allowing a user to input a non-URL text string into a "translator input window" overlaid on a browser. The system then determines the most likely desired webpage and displays it directly, without requiring additional user intervention like selecting from a list of search results.

3. Grounds for Unpatentability

Ground 1: Obviousness over Seltzer and Belfiore - Claims 1, 2, 5, 8, 9, and 10 are obvious over Seltzer in view of Belfiore.

  • Prior Art Relied Upon: Seltzer (“The AltaVista Search Revolution,” 1997) and Belfiore (Patent 6,009,459).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seltzer disclosed the AltaVista search engine, which featured a standard HTML search field within a webpage for entering non-URL text strings to receive a list of search results. Belfiore disclosed a browser "Autosearch" feature where, if a user enters text that is not a valid URL into the browser's address bar, the system automatically formats a search query and redirects the browser directly to the single "most relevant web site discovered in the search," bypassing the traditional list of results. The combination of Seltzer’s search interface with Belfiore’s direct-to-top-result functionality allegedly taught all limitations of the independent claims.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to enhance the user experience. Adding Belfiore's convenient "Autosearch" feature as an option to a standard search engine like Seltzer's AltaVista would satisfy market demand for more efficient searching, particularly for novice users who were unfamiliar with proper URL syntax and preferred being taken directly to the most likely result.
    • Expectation of Success: Combining the known browser functionality of Belfiore with the well-established web search interface of Seltzer was a predictable integration of existing software features to achieve a known goal.

Ground 2: Obviousness over Seltzer, Belfiore, and Osaku - Claims 7, 13, and 14 are obvious over Seltzer and Belfiore in further view of Osaku.

  • Prior Art Relied Upon: Seltzer, Belfiore (Patent 6,009,459), and Osaku (Patent 6,061,738).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Seltzer and Belfiore combination by adding the teachings of Osaku. Petitioner contended that Osaku disclosed a translator entity that resides locally on the user's computer (claim 7) to improve search efficiency by using locally stored data and user-specific habits. Osaku also taught using a domain name server (DNS) to resolve simplified network addresses or aliases into URLs (claims 13 and 14), which could be combined with the primary references to enhance the speed and functionality of the translation process.
    • Motivation to Combine: A POSITA would incorporate Osaku’s teachings to improve the performance of the Seltzer/Belfiore system. Implementing client-side processing, as taught by Osaku, would increase the speed of information access and allow for search result personalization based on local user data, which were known benefits and key objectives in any search system.

Ground 3: Obviousness over Seltzer, Belfiore, and Breese - Claims 3, 4, 6, 11, and 12 are obvious over Seltzer and Belfiore in further view of Breese.

  • Prior Art Relied Upon: Seltzer, Belfiore (Patent 6,009,459), and Breese (Patent 6,006,218).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added the teachings of Breese to the primary Seltzer/Belfiore combination to address dependent claims related to the use of statistical data in ranking results. Breese disclosed detailed search methodologies for ranking results based on "knowledge probability estimates," which considered statistical factors such as previous web searches by the user (claim 3), the popularity of web pages based on traffic volume and visits from a plurality of users (claim 4), frequency of visits (claim 11), and number of visits (claim 12).
    • Motivation to Combine: A POSITA would be motivated to use the known search ranking methodologies of Breese to refine the process of determining the "most likely" desired webpage in the Seltzer/Belfiore system. Breese provided a known, available toolkit for implementing the ranking and selection function that was central to Belfiore's "Autosearch" feature, thereby improving its accuracy and relevance.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 15 and 16 based on the combination of Seltzer, Belfiore, and Osaku in further view of Breese, arguing that the statistical ranking methods of Breese were equally applicable to the DNS-based system established by the other references.

4. Key Claim Construction Positions

  • "translator input window" / "overlaid on a portion of the browser window": Petitioner argued that this petition's grounds were based on the Patent Owner's litigation position, which construes "translator input window" to encompass a simple HTML <input> field within a webpage and construes "overlaid" to mean merely "displayed on" any part of the browser, including the main content area. Petitioner contended that while this construction was improperly broad, the claims were obvious even under this interpretation, as Seltzer's AltaVista search field would meet the limitation.
  • "the domain name server sends the web page..." (Claim 14): Petitioner asserted this phrase is technically inoperable because a DNS only translates domain names to IP addresses and does not send webpages. For the purposes of the IPR, Petitioner proposed construing the phrase to mean the DNS "enables retrieval" of the webpage, to render the claim operable for analysis against the prior art.