RPX Corp v. Coding Technologies LLC

1. Case Identification

• Case #: IPR2018-00857
• Patent #: 8,540,159
• Filed: March 28, 2018
• Petitioner(s): RPX Corporation
• Patent Owner(s): Coding Technologies, LLC
• Challenged Claims: 1-15

2. Patent Overview

• Title: Method for Providing Mobile Service Using Code-Pattern
• Brief Description: The ’159 patent discloses a method and system where a user terminal (e.g., a mobile phone) obtains a photographic image of a code pattern, processes the image to extract encoded information such as a URL, transmits a request to a server based on that information, and receives content in response.

3. Grounds for Unpatentability

Ground 1: Obviousness over a Single Reference - Claims 1-4, 8-11, and 15 are obvious over Lawandy.

• Prior Art Relied Upon: Lawandy (Application # 2002/0023218).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Lawandy teaches all elements of the independent claims. Lawandy discloses a hand-held device that uses a camera to obtain an image of a digitally watermarked barcode (a "code pattern"). The device processes the image to remove distortion, decodes the watermark to extract code information (such as a WWW address), transmits this information to an external data processor ("server") to access a database, and receives responsive content for display. Lawandy also discloses that the content can include images and text and that the decoded information can be a URL, mapping to the dependent claims.
  • Motivation to Combine (for §103 grounds): As this is a single-reference ground, no motivation to combine is required. Petitioner asserted that Lawandy alone renders the claims obvious.
  • Key Aspects: Petitioner contended that Lawandy's disclosure of a complete, self-contained system for capturing, decoding, and acting upon information encoded in an image meets every limitation of the challenged independent claims.

Ground 2: Obviousness over Lawandy in view of Wellner - Claims 5-7 and 12-14 are obvious over Lawandy and Wellner.

• Prior Art Relied Upon: Lawandy (Application # 2002/0023218) and Wellner (Patent 5,640,193).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses claims requiring a "service identifier" that indicates a service type. Petitioner asserted Lawandy provides the base system of using a code pattern to access web content. Wellner was introduced to teach encoding a specific "service identifier" within a barcode that allows a user to select from various services (e.g., movie previews, news access, product instructions). The combination allegedly teaches a system where a request message includes both code information (from Lawandy) and a service identifier (from Wellner) to retrieve different types of content from a database.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Wellner’s service identification method with Lawandy's multi-service system to improve scalability and efficiency. Grouping Lawandy's various services (e.g., database access, identity verification) into types identified by Wellner's service identifiers would allow requests to be distributed more efficiently among different back-end servers.
  • Expectation of Success: The combination involved applying a known technique (service identifiers) to a similar system (multi-service, code-based access) to achieve the predictable result of an organized, multi-service platform.

Ground 3: Obviousness over Dougherty in view of Rhoads - Claims 1-15 are obvious over Dougherty and Rhoads.

• Prior Art Relied Upon: Dougherty (Patent 6,076,734) and Rhoads (WO/2000/070585).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Dougherty discloses a base system for using a sensor to read a code pattern on a physical object, decode a URL, and use a computer to download linked data from the internet. However, Dougherty focuses on "spectral encoding" and lacks detail on processing common barcodes with modern devices. Rhoads was argued to supply these missing details, teaching the use of digital cameras in cell phones and laptops to capture and process 1D and 2D barcodes. For claims requiring a "service identifier," Rhoads further teaches a data payload with CLASS and DNS ID fields that function to identify a service type and route a request to a corresponding server that can provide different types of content.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Rhoads' detailed teachings on barcode image processing with Dougherty’s general system to provide a complete, practical implementation using standard, ubiquitous imaging devices like cell phone cameras. Furthermore, a POSITA would look to Rhoads' more robust encoding schemes (e.g., 2D barcodes) to overcome the data capacity and sensitivity limitations inherent in Dougherty’s spectral encoding method.
  • Expectation of Success: Combining Rhoads with Dougherty would yield predictable results, as it primarily involved supplying known, specific implementation details for a general system to improve its functionality and overcome its disclosed limitations.

4. Key Claim Construction Positions

• "code pattern" (claims 1, 5, 8, 12, 15): Petitioner proposed this term should be construed to mean "a machine-readable, via image processing, pattern representing encoded data." This construction is broad enough to encompass not only traditional barcodes but also the digital watermarks discussed in the prior art.
• "process[ing]...the photographic image...to extract the code pattern..." (claims 1, 8, 15): Petitioner argued this phrase should be construed to mean "at least processing the photographic image to recognize the code pattern therein." This was a critical point, as the specification describes recognizing a code pattern as part of the "processing" step, while "extracting" is described as part of the subsequent "decoding" step. This construction allowed Petitioner to map prior art that "recognizes" or "locates" a code pattern to this claim limitation.
• "service identifier" (claims 5, 6, 12, 13): Petitioner proposed this term means "at least an identifier representing a type of service to be provided," consistent with the patent's specification and claim language.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-15 of Patent 8,540,159 as unpatentable.