PTAB

IPR2018-00858

RPX Corp v. Coding Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

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

3. Grounds for Unpatentability

Ground 1: Obviousness over Lawandy, Wellner, and Dorai - Claims 16 and 17 are obvious over Lawandy in view of Wellner and further in view of Dorai.

  • Prior Art Relied Upon: Lawandy (Application # 2002/0023218), Wellner (Patent 5,640,193), and Dorai (Patent 7,121,469).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lawandy taught the core method of claim 16: a hand-held device captures an image of a code (e.g., a digital watermark or barcode), processes it to extract information, transmits this information to an external server to access a database, and receives related content back for display. This maps to the claim steps of obtaining an image, processing it to extract "characteristic information," transmitting a request, and receiving content. Petitioner asserted Wellner supplied the missing concept of using a "service identifier" within the barcode data to allow a single system to provide multiple distinct services (e.g., movie previews, news access). Dorai was introduced to teach the flexibility of performing image processing either locally on the user device or remotely on a server, a known design choice to balance processing load, device cost, and bandwidth.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Lawandy's base system with Wellner's service identifier concept as a known technique to improve the scalability and efficiency of a multi-service, barcode-accessed system. Adding Dorai’s teachings on local versus remote processing would be a simple design choice to optimize system performance based on predictable cost and bandwidth trade-offs.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, as the combination involved applying known techniques (service identifiers, flexible processing locations) to similar systems to achieve predictable improvements in efficiency and functionality.

Ground 2: Obviousness over Dougherty and Rhoads - Claims 16 and 17 are obvious over Dougherty in view of Rhoads.

  • Prior Art Relied Upon: Dougherty (Patent 6,076,734) and Rhoads (WO 2000/070585).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Dougherty taught a method of interfacing with a computer using an encoded physical medium (e.g., barcode) to access content from a network like the internet. A sensor in Dougherty captures information, decodes it (e.g., a URL), and transmits it to a computer system, which then downloads the desired data. While Dougherty disclosed using barcodes, it focused on "spectral encoding." Rhoads was argued to provide the necessary implementation details, teaching in detail how to use a digital camera on a cell phone or PDA to process images of various codes (including 1D and 2D barcodes) to link to internet resources. Together, Dougherty provided the system framework and Rhoads provided the specific, well-known barcode processing method.
    • Motivation to Combine: A POSITA would be motivated to combine Rhoads' detailed teachings on barcode imaging and processing with Dougherty's system. This combination would not be a substitution but rather the application of specific, well-known implementation details (from Rhoads) to a conceptual system (Dougherty's), yielding predictable results. This would also overcome the data capacity limitations of Dougherty's spectral encoding by incorporating Rhoads' more robust encoding schemes like 2D barcodes.
    • Expectation of Success: The combination would predictably result in a functional system with the advantages of using standard, ubiquitous imaging devices like digital cameras, leading to lower cost and wider applicability.

4. Key Claim Construction Positions

  • "characteristic information" (claims 16, 17): Petitioner argued this term, which does not appear in the specification, should be construed to mean "at least a characteristic that is machine-readable via image processing." Because this term is used in the claims in a manner analogous to "code pattern" but without a "decoding" step, Petitioner asserted it is broader and encompasses "code pattern" or "code information." This construction was critical to map prior art disclosing "code patterns" onto the challenged claims reciting "characteristic information."
  • "process[ing]...the photographic image...to extract the code pattern" (claims 1, 8, 15, 16): Petitioner asserted this phrase means at least processing the image to recognize the code pattern therein. The petition argued the specification consistently describes "recognizing" a code pattern as the processing step, while "extracting" refers to obtaining the code information from the already-recognized pattern, often as part of decoding.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 16 and 17 of the ’159 patent as unpatentable.