PTAB

IPR2018-00408

Snap Inc v. Vaporstream Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electronic Message Recipient Handling System and Method with Media Component and Header Information Separation
  • Brief Description: The ’111 patent discloses a method for handling electronic messages to achieve "reduced traceability." The invention's core concept involves using a recipient's mobile device to present message header information and the corresponding message content on separate, non-simultaneous displays, thereby preventing a single screen capture from creating a complete record of the communication.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4, and 5 are obvious over Wren in view of Berger

  • Prior Art Relied Upon: Wren (Application # 2005/0021803) and Berger (Application # 2003/0152203).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wren discloses the majority of limitations in independent claim 1. Wren teaches a "one-touch" system for sending "movie messages" to a recipient's mobile device. Upon receipt, Wren’s system provides a "first display" (Fig. 9A) showing only header information (e.g., "From: Jane Doe," "Time: 9:30AM") and a "second display" (Fig. 9B) that, upon user selection, shows the media content (the movie). Petitioner asserted that these sequential, separate displays meet the claimed "plurality of reduced traceability displays" that prevent a single screen capture. The petition contended that Wren's disclosure of handling a single message notification was deficient only in its lack of a "message list." Berger was argued to supply this element by disclosing a mobile device interface that displays a list of multiple messages (Fig. 4), with each entry showing header-like information (sender and time), from which a user can select a message for viewing. Combining these teachings rendered claim 1 obvious. Dependent claims 4 (content without header) and 5 (media is video/audio) were argued to be inherently taught by Wren's separate displays of video messages.
    • Motivation to Combine: A POSITA would combine Wren and Berger to provide a distinct and predictable improvement to Wren's user interface. It was a well-known practice in electronic messaging to manage multiple messages via a list, as taught by Berger, rather than handling each notification individually. Both Wren and Berger are analogous art, addressing the common problem of presenting message information on mobile devices with limited screen space. Furthermore, Berger’s teachings offered additional benefits, such as optimizing content for the target device and enhancing security by using hashed URLs, which would provide further motivation to improve Wren’s system.
    • Expectation of Success: A POSITA would have had a high expectation of success. Integrating a standard message list feature from a mobile messaging system (Berger) into another mobile messaging application (Wren) was a routine and predictable modification that involved applying a known technique to a similar system to yield predictable results.

Ground 2: Claims 9, 10, and 11 are obvious over Wren in view of Berger and Hanna

  • Prior Art Relied Upon: Wren (Application # 2005/0021803), Berger (Application # 2003/0152203), and Hanna (Patent 7,054,905).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that adding the teachings of Hanna to the Wren/Berger combination rendered the dependent claims obvious. For claim 9, which requires that header information and message content are "communicated over the network separately," Hanna discloses a method of replacing a large email attachment with a URL pointing to the content on a server. An initial message containing the header information and the URL is sent to the recipient; the recipient then uses that URL to retrieve the actual content in a second, separate network communication. This directly maps to the claim limitation. For claim 10, which requires "deleting the message content...from the server computer," Hanna explicitly teaches that the server can delete the stored attachment after it has been retrieved by all recipients or after a set time, thereby conserving server storage. For claim 11, which requires deletion to occur "after said providing a second display," Petitioner argued that Hanna's teaching of deleting after retrieval satisfies this limitation. In the combined system, the "second display" (Wren's video playback) can only be provided after the content is retrieved from the server via Hanna's URL method; therefore, deleting the content after retrieval is necessarily deleting it after the second display is provided.
    • Motivation to Combine: A POSITA would have been highly motivated to incorporate Hanna's teachings to solve the well-known drawbacks of sending large media files—like Wren's movie messages—as direct attachments. Hanna's URL-based delivery system provides numerous compelling advantages, including conserving network bandwidth, reducing server storage load, preventing accidental forwarding of sensitive content, and improving access control. These benefits directly address the practical limitations of sending video files to mobile devices and provided a strong motivation to adapt the Wren/Berger system with Hanna's more sophisticated content delivery mechanism.
    • Expectation of Success: The combination was technologically straightforward. All three references operate in the same field of electronic messaging and use compatible, well-understood network protocols. A POSITA would have readily understood how to implement Hanna's URL-based retrieval system into the Wren/Berger mobile messaging framework with a high expectation of success.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4, 5, and 9-11 of Patent 9,338,111 as unpatentable.