PTAB

IPR2018-00244

TicketNetwork Inc v. CEATS Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Maintaining Coherency of Data Entries
  • Brief Description: The ’867 patent discloses a computer-implemented system for managing and selling tickets for events at a venue. The system maintains seat inventory in a database and provides an interactive user interface, such as a graphical seat map, for users to view seat availability, select seats, and complete purchases over a network.

3. Grounds for Unpatentability

Ground 1: Obviousness over NFB and the ’637 patent - Claims 1-9 are obvious over NFB in view of Patent [5,436,637](https://ai-lab.exparte.com/case/ptab/IPR2018-00244/doc/1007).

  • Prior Art Relied Upon: NFB (a 1998 student report describing the "Nordisk Film Biografer" internet ticket booking system) and Patent 5,436,637 (“’637 patent”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that NFB, a publicly available report from 1998, discloses a complete internet-based movie ticket booking system that meets most limitations of the challenged claims. The NFB system included a server, a database for seat inventory, and a client-side interface that displayed a graphical seat map. On this map, reserved seats were marked in red and available seats could be selected by a user with a mouse click, after which they were marked in green. The system was designed for simultaneous users and updated seat availability to prevent double-booking. Petitioner asserted that the only key element of the independent claims not explicitly in NFB is the "mouse-over" functionality, where information about available seats is transmitted in response to a user hovering the mouse cursor over a seat. This element was added during prosecution to overcome prior art.
    • Motivation to Combine: Petitioner contended that the ’637 patent explicitly teaches using mouse-over events to display descriptive text or "hints" about an on-screen object without requiring a click. A POSITA would combine the NFB system with the mouse-over feature of the ’637 patent to enhance user experience. Mouse-over functionality was a well-known, computationally efficient alternative to clicking for providing information. Modifying NFB to display seat details (e.g., seat number, price) upon mouse-over would have been a simple substitution of one known user interface element for another to obtain the predictable result of a more intuitive and responsive system.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination, as it involved implementing a standard graphical user interface feature into an existing web-based system architecture, both of which were well-understood technologies at the time.

Ground 2: Obviousness over NFB, the ’637 patent, and the ’894 patent - Claim 5 is obvious over NFB in view of Patent [5,436,637](https://ai-lab.exparte.com/case/ptab/IPR2018-00244/doc/1007) and further in view of Patent [5,565,894](https://ai-lab.exparte.com/case/ptab/IPR2018-00244/doc/1020).

  • Prior Art Relied Upon: NFB, Patent 5,436,637 (“’637 patent”), and Patent 5,565,894 (“’894 patent”).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addresses claim 5, which requires the venue to be a "stadium." The primary combination of NFB and the ’637 patent provides the base ticketing system as argued in Ground 1. Petitioner introduced the ’894 patent because it explicitly discloses a ticket kiosk with a computer-based touchscreen for selecting seats in a stadium. The interface in the ’894 patent shows a graphical representation of stadium seating, where users can touch a button corresponding to a seat to purchase a ticket.
    • Motivation to Combine: Petitioner argued that while NFB focused on movie theaters, its underlying technology was not limited to that venue type. A POSITA would be motivated to adapt the ticketing system of NFB and the ’637 patent to other venues with reserved seating, including stadiums, to provide a more convenient and comprehensive remote booking service. The ’894 patent demonstrates that applying automated, graphical seat-selection systems to stadiums was already known in the art. This modification would expand the system's commercial applicability, reduce labor costs, and keep pace with technological advances, making it an obvious extension of the primary combination.
    • Expectation of Success: The expectation of success would be high, as applying a known online ticketing methodology to a different but analogous venue type (stadiums instead of theaters) presents no new technical challenges.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9 of the ’867 patent as unpatentable.