PTAB

IPR2018-01749

Ralph Lauren Corp v. Lexos Media IP LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Server System and Method for Modifying a Cursor Image
  • Brief Description: The ’102 patent describes a client-server system for online advertising that modifies a standard cursor image into a "specific image," such as a brand logo or product icon. The cursor's appearance changes based on on-screen content to deliver advertising in a manner intended to be less intrusive than traditional banner ads.

3. Grounds for Unpatentability

Ground 1: Claims 70-73 are obvious over Malamud and Anthias.

  • Prior Art Relied Upon: Malamud (Patent 6,437,800) and Anthias (Patent 5,920,311).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Malamud taught the core inventive concept: modifying a standard cursor into a content-aware "information cursor" that displays a specific image (e.g., a graphical preview of an object's contents) when pointing to an on-screen object. This modification is handled by the local operating system (OS). Petitioner contended that Anthias, in turn, taught implementing cursor modifications within a client-server architecture, where a "client" system instructs a "server" system (the user terminal) to change the cursor's shape based on its location. The combination of Malamud's content-aware cursor with Anthias's networked architecture allegedly rendered the claimed system obvious, with Malamud's OS corresponding to the "remote user terminal" and its application window procedure corresponding to the "server."
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) seeking to adapt Malamud's local cursor modification system for use on websites would be motivated to consult Anthias. Anthias explicitly addresses managing graphical elements, including cursors, over a network, thereby providing a clear roadmap for implementing Malamud's functionality in the client-server environment of the internet.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success, as the combination involved applying a known networking solution (Anthias) to a known user interface feature (Malamud) to achieve a predictable result in a networked environment.

Ground 2: Claims 70-73 are obvious over Baker and Anthias.

  • Prior Art Relied Upon: Baker (Patent 5,715,416) and Anthias (Patent 5,920,311).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Baker disclosed an alternative basis for the core cursor modification concept. Baker taught an animated character that functions as the cursor, changing its appearance and animation (the "specific image") based on its movement and interaction with on-screen icons (e.g., walking, waving, or picking up an icon). This system, like Malamud's, was described as operating locally. The combination with Anthias provided the necessary client-server framework, with Baker's pictorial UI system acting as the "server" and the local OS as the "remote user terminal."
    • Motivation to Combine: The motivation was parallel to Ground 1. Petitioner argued a POSITA wanting to deploy an interactive, animated cursor like the one in Baker on a website would be motivated to use the client-server cursor management techniques taught by Anthias to enable the functionality over a network.
    • Expectation of Success: Similar to the first ground, Petitioner argued the combination represented a straightforward application of a known networking technique to a graphical interface feature to make it functional in a predictable, networked environment, and thus success would have been expected.

4. Key Claim Construction Positions

  • The petition proposed constructions for several key terms to frame its invalidity arguments and demonstrate that the prior art met the claim limitations.
  • "cursor image" / "initial cursor image": Petitioner argued this term meant "a standard/generic icon controlled by the operating system." This construction anchors the invention in modifying a conventional cursor, a feature Petitioner asserted was well-known in the prior art.
  • "specific image": Proposed as "a predetermined image, different from the cursor image, that is drawn in its entirety in place of the cursor image." This construction emphasizes a complete replacement of the cursor, which Petitioner argued was disclosed by the preview cursors of Malamud and the animated characters of Baker.
  • "cursor display instruction": Defined as "information transmitted by a server computer to a remote terminal which triggers the cursor display code to change the cursor image." Petitioner mapped this claim element to messages passed between system components in the prior art, such as a message from a window procedure to the OS containing a pointer to the new cursor's image data.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 70-73 of the ’102 patent as unpatentable under 35 U.S.C. §103.