PTAB

IPR2018-00244

TicketNetwork, Inc. v. CEATS, Inc

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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 and method for maintaining seat inventory for events at a venue. The technology involves providing users with access to a database via an interactive seat map, allowing them to view available seats, select seats for purchase, and receive confirmation, thereby ensuring data coherency as inventory changes.

3. Grounds for Unpatentability

Ground 1: Claims 1-9 are obvious over NFB in view of Patent 5,436,637

  • Prior Art Relied Upon: NFB (a 1998 student project report titled "Ticket Booking System: Nordisk Film Biografer") and Patent 5,436,637 (“the ’637 patent”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that NFB, a publicly available report detailing an internet-based movie ticket booking system, discloses the core features of the challenged claims. This includes a computer system with a database for seat inventory, a web server accessible by multiple users, and a graphical user interface (GUI) with an interactive seat map. NFB's system allowed a user to query for available seats, view them on a map (with unavailable seats marked), select seats via mouse click, and have the system lock those seats in the database to prevent double-booking. Petitioner argued that the only key element not explicitly detailed in NFB is transmitting available seat information in response to a mouse-over event. This limitation, Petitioner contended, is taught by the ’637 patent, which discloses a GUI method for providing "hints" (descriptive text) about on-screen objects when a cursor is moved over them, without requiring a click.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine NFB with the ’637 patent's mouse-over functionality as a simple substitution of one known method (clicking) for another (mouse-over) to obtain information. The ’637 patent taught mouse-over as a known, intuitive, and computationally efficient way to provide users with information. A POSITA would have been motivated to modify the NFB system to display seat details (e.g., seat number, price) upon mouse-over to enhance user experience and provide information more quickly, which would have been a predictable improvement.
    • Expectation of Success: The combination was argued to be a simple substitution of one known UI element for another to achieve a predictable result. A POSITA would have had a reasonable expectation of success in integrating the well-understood mouse-over hint feature of the ’637 patent into the web-based ticketing framework of NFB.

Ground 2: Claim 5 is obvious over NFB in view of Patent 5,436,637 and further in view of Patent 5,565,894

  • Prior Art Relied Upon: NFB, Patent 5,436,637, and Patent 5,565,894 (“the ’894 patent”).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination in Ground 1 to specifically address the limitation in dependent claim 5 that the venue is a "stadium." While NFB focuses on movie theaters, Petitioner argued that the ’894 patent explicitly teaches the application of this type of ticketing technology to a stadium. The ’894 patent discloses a ticket kiosk with a computer-based touchscreen that displays an aggregation of buttons representing a section of seats in a stadium, allowing users to select seats for purchase.
    • Motivation to Combine: A POSITA, having combined NFB and the ’637 patent to create an online ticketing system with mouse-over functionality, would have been motivated to apply this system to other types of venues like stadiums, as taught by the ’894 patent. The motivation would be to expand the system's commercial applicability to a wider variety of events. Applying a known online booking system to a different but analogous venue (a stadium instead of a theater) was presented as an obvious design choice to serve a larger market.
    • Expectation of Success: Implementing the ticketing system for a stadium would have been a predictable application of the combined teachings, as the underlying principles of managing reserved seat inventory are the same regardless of whether the venue is a theater or a stadium.

4. Key Technical Contentions

  • Collateral Estoppel from Prior Litigation: Petitioner dedicated significant argument to the preclusive effect of a prior Federal Circuit decision in CEATS, Inc. v. Cont'l Airlines, Inc.. That case involved patents from the same family as the ’867 patent with an identical specification. Petitioner asserted that the Federal Circuit affirmed a finding that the Expedia 2.0 prior art system disclosed key claim elements, including "mouse-over functionality" and a "database storing a plurality of entries denoting seat availability." Petitioner argued that the Patent Owner (CEATS) is therefore collaterally estopped from re-litigating whether these features were known in the prior art, substantially strengthening the obviousness arguments presented in the petition.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9 of Patent 7,548,867 as unpatentable under 35 U.S.C. §103.