Ralph Lauren Corp v. Lexos Media IP LLC

1. Case Identification

• Case #: IPR2018-01755
• Patent #: 6,118,449
• Filed: September 18, 2018
• Petitioner(s): Ralph Lauren Corporation
• Patent Owner(s): Lexos Media IP, LLC
• Challenged Claims: 1-3, 5-7, 12-15, 27-29, 31-33, 38-41, 53-56, 58-63, 72-75, and 77-82

2. Patent Overview

• Title: Server System and Method for Modifying a Cursor Image
• Brief Description: The ’449 patent discloses a client-server system for modifying a standard graphical user interface (GUI) cursor into a "specific image" for online advertising. The system transmits cursor modification instructions and image data, often embedded in HTML documents, from a server to a user's terminal to change the cursor's appearance based on onscreen content.

3. Grounds for Unpatentability

Ground 1: Obviousness over Malamud and Anthias - Claims 1, 7, 15, 27, 33, 41, 53-54, 63, 72-73, 82 are obvious over Malamud in view of 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 disclosed the core concept of modifying a cursor based on onscreen content. Malamud taught an "information cursor" that changes to display additional information (e.g., a graphical preview of a file's contents) when the user points to an object. Petitioner asserted this modification from a standard pointer to a preview image met the limitations of modifying a "cursor image" to a "specific image." The bitmap data for the preview image constituted the claimed "cursor image data," and the operating system (OS) functions that retrieved and displayed this bitmap constituted the "cursor display code."
  • Motivation to Combine: Anthias taught a distributed data processing system using a client-server model (specifically, the X-Windows system) where a remote "client" (server) sends graphical instructions to a local "server" (terminal) to manage and draw UI elements, including changing a cursor's shape as it moves over different areas. Petitioner contended a person of ordinary skill in the art (POSITA) would combine Malamud's content-aware cursor with Anthias's well-known client-server architecture to implement such a feature over a network, a predictable and logical extension.
  • Expectation of Success: The combination involved applying a known network architecture (Anthias) to a known UI feature (Malamud), which would have yielded predictable results.

Ground 2: Obviousness over Baker and Anthias - Claims 1, 7, 15, 27, 33, 41, 53-54, 63, 72-73, 82 are obvious over Baker in view of Anthias.

• Prior Art Relied Upon: Baker (Patent 5,715,416) and Anthias (Patent 5,920,311).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground presented Baker as an alternative to Malamud for the primary reference. Petitioner argued Baker taught an animated character that functions as the cursor and changes its appearance and animation based on its location and interaction with onscreen icons (e.g., walking, picking up an icon, waving). Petitioner contended this animated character met the "cursor image" limitation, and its various animated states (e.g., holding an icon) constituted the "specific image." The animation frames and character data stored in a "character_model" data structure corresponded to the "cursor image data" and "cursor display instruction."
  • Motivation to Combine: The motivation was identical to Ground 1: a POSITA would have been motivated to implement Baker's dynamic, animated cursor within the client-server framework taught by Anthias to provide such graphical UI elements over a network. This was argued to be an obvious design choice for developers transitioning from standalone applications to networked environments.
  • Expectation of Success: As with the first ground, combining Baker's UI concept with Anthias's standard networking architecture was presented as a straightforward task with a high expectation of success.

Ground 3: Obviousness over Malamud, Anthias, and Nielsen - Claims 12, 14, 38, 40, 60, 62, 79, 81 are obvious over Malamud and Anthias in view of Nielsen.

• Prior Art Relied Upon: Malamud (Patent 6,437,800), Anthias (Patent 5,920,311), and Nielsen (Patent 5,991,781).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground built upon the combination of Malamud and Anthias by adding Nielsen to address claims requiring the content information to be transmitted in HTML files and processed by a browser. Nielsen disclosed a system for enhancing web pages by detecting a cursor's position over defined areas in an HTML image map and triggering an associated action (playing an audio clip). Petitioner asserted Nielsen explicitly taught transmitting HTML webpages over a network to a client computer with a browser that is responsive to cursor location.
  • Motivation to Combine: A POSITA seeking to implement the content-aware cursor of Malamud in a web environment would naturally have looked to references like Nielsen, which explicitly taught handling cursor events within HTML documents and browsers. Combining these teachings was presented as an obvious path to adapt existing UI concepts for the burgeoning World Wide Web.
  • Key Aspects: The addition of Nielsen specifically targeted limitations related to web-based implementation, such as transmitting content in "HTML files" (claim 12) and using a "browser application" (claim 14).

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations incorporating Baker for advertising purposes (Malamud/Anthias/Baker) and for web-based advertising (Malamud/Anthias/Nielsen/Baker and Baker/Anthias/Nielsen), which relied on similar motivations to combine.

4. Key Claim Construction Positions

• "cursor image" / "initial cursor image": Petitioner proposed this term means "a standard/generic icon controlled by the operating system to show the position of a pointing device's pointer on the user terminal's display." This construction was intended to establish a baseline of a conventional cursor (e.g., arrow, hourglass) that is then modified by the invention.
• "specific image" / "specific cursor image": Petitioner proposed this term means "a predetermined image, different from the cursor image, that is drawn in its entirety in place of the cursor image." This construction emphasized a complete replacement of the standard cursor with a new, distinct image (e.g., a product logo), which was central to mapping the prior art's graphical previews and animated characters to the claims.
• "modifying a cursor image": Petitioner proposed this term means "changing the shape and appearance of a cursor image." This broad construction was critical for arguing that both Malamud's addition of an "information portion" and Baker's character animations constituted the claimed modification.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and cancellation of claims 1-3, 5-7, 12-15, 27-29, 31-33, 38-41, 53-56, 58-63, 72-75, and 77-82 of the ’449 patent as unpatentable under 35 U.S.C. §103.