PTAB

IPR2018-01131

RPX Corp v. Publishing Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Managing Information Content
  • Brief Description: The ’342 patent describes a network-based system for managing information content. The technology allows a user to access a content management website to designate at least one external data source, which then automatically provides data to generate a separate, mobile-accessible website.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Underwood - Claims 1, 5, 9-11, 16-20 are unpatentable under 35 U.S.C. §102 or, alternatively, are obvious under 35 U.S.C. §103 over Underwood.

  • Prior Art Relied Upon: Underwood (Patent 7,668,913).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Underwood disclosed every limitation of the challenged claims. Underwood taught a "Universal Content Manager" (UCM) system with "Definer" software that functioned as the claimed content management website, accessible to a user via a first URL. This Definer software allowed a user to designate external data sources, termed "Definer External Components" (DXCs), which could be developed by third parties. The system then generated and published a complete website, which could be specifically formatted for "reduced capacity" devices like mobile phones. Petitioner contended this published website was generated at a second, distinct URL specified by the user and was configured to automatically retrieve data from the designated DXCs at runtime, thus meeting all limitations of independent claim 1. Dependent claims were allegedly met by Underwood’s disclosure of using file sources (static HTML pages) for DXCs (claim 5) and its features for uploading images and selecting content options (claims 9-11).
    • Motivation to Combine: For the alternative obviousness ground, Petitioner argued that even if Underwood did not explicitly teach generating a mobile website, it would have been obvious to do so. Underwood recognized that mobile devices have "reduced capacity," and a person of ordinary skill in the art (POSITA) would have been motivated to use Underwood’s formatting tools to create websites optimized for such devices to ensure effective display.
    • Expectation of Success: A POSITA would have had a high expectation of success, as Underwood provided a complete software solution for website generation and formatting, making its application to the known challenge of mobile display a predictable implementation.

Ground 2: Obviousness over Austin and Chang - Claims 1, 4-5, 9-11, 16-18, and 20 are obvious over Austin in view of Chang.

  • Prior Art Relied Upon: Austin (International Publication No. WO 02/03243) and Chang (Patent 7,590,681).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Austin taught a Content Management System (CMS) for retailers to create and manage mobile-accessible e-commerce sites. Austin's system allowed retailers (users) to integrate external data, such as legacy stock control databases or content from existing websites via a "reverse proxy" model. The system then generated WAP-accessible "shop sites" for shoppers. However, Petitioner argued Austin did not explicitly disclose that its CMS and the generated mobile sites were accessible via different URLs. To supply this element, Petitioner pointed to Chang, which taught a system with a "management server" accessible via a traditional web browser at one URL (e.g., www.atroad.com) that allowed a user to customize content for a mobile website accessible through a separate portal at a different URL (e.g., 'Myweb2go').
    • Motivation to Combine: A POSITA implementing Austin's CMS would combine its teachings with Chang's approach to provide separate, logical access points for different user types: one URL for retailers to access the administrative CMS and a different URL for shoppers to access the public-facing mobile website. This separation was a well-known and obvious design choice for managing security, functionality, and web traffic, making the administrative backend distinct from the consumer storefront.
    • Expectation of Success: The combination involved applying a conventional web architecture principle (using different URLs for admin and public sites) to Austin's CMS. A POSITA would have reasonably expected this integration to be successful and result in a more organized, secure, and user-friendly system with predictable results.

  • Additional Grounds: Petitioner asserted obviousness challenges for claim 19 over Underwood in view of Tsakiris (Application # 2001/0034746), and over Austin and Chang in view of Tsakiris, to supply the explicit teaching of a "network interface."

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the phrase "the mobile web site being accessible independently of the content management web site."
    • Proposed Construction: "pages of the mobile web site are accessible using a URL that is different from a URL used to access pages of the content management web site."
    • Rationale: Petitioner contended this construction was compelled by the patent's specification, which illustrates separate home pages for the management site and the mobile site. Furthermore, the prosecution history of a parent application showed that the applicant distinguished prior art by adding the limitation that the mobile site is identified by a second URL different from the first, specifically "so as to allow" independent access.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4-5, 9-11, and 16-20 of the ’342 patent as unpatentable.