PTAB

IPR2019-00127

Canon USA Inc v. Cellspin Soft Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Automatic Multimedia Upload for Publishing Data and Multimedia Content
  • Brief Description: The ’698 patent is directed to a system and method for utilizing a digital data capture device (e.g., a digital camera) in conjunction with a mobile device. The system wirelessly transfers media files from the camera to the mobile device over a short-range connection (e.g., Bluetooth) for subsequent upload to one or more websites.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hiroishi and Takahashi - Claims 1-20 are obvious over Hiroishi in view of Takahashi.

  • Prior Art Relied Upon: Hiroishi (JP Application # 2003-60953), Takahashi (JP Application # 2005-303511).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hiroishi teaches a base system where a cellular phone remotely controls a digital camera via a short-range wireless connection like Bluetooth. This control includes instructing the camera to acquire new media, transferring the media file to the phone, and providing a GUI on the phone to initiate deletion of the original file from the camera's memory. Petitioner asserted that while Hiroishi discloses forwarding the image file to a generic "terminal," it does not explicitly teach uploading it to a user media publishing website using HTTP. Takahashi was argued to supply this limitation by teaching a system where a mobile device uses HTTP to upload image data, along with user-identifying information, to a server that processes and publishes the image on a web page.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine these references to improve upon Hiroishi's system. At the time of the invention, sharing photos on websites was a common and desirable activity. A POSITA would integrate Takahashi’s efficient and standardized HTTP upload functionality into Hiroishi’s camera-to-phone transfer system to provide a complete, seamless solution for publishing images from a dedicated camera onto the internet, a predictable and beneficial improvement.
    • Expectation of Success: Petitioner asserted a high expectation of success because the combination would only require a straightforward software modification. Packaging the image data received by the phone in Hiroishi into an HTTP message for upload, as taught by Takahashi, was well within the ordinary skill of a POSITA.

Ground 2: Obviousness over Hollstrom and Takahashi - Claims 1, 3-5, 7-8, 10-13, and 15-20 are obvious over Hollstrom in view of Takahashi.

  • Prior Art Relied Upon: Hollstrom (Patent 6,763,247), Takahashi (JP Application # 2005-303511).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Hollstrom as an alternative primary reference that teaches a mobile device with an application for remotely controlling a wirelessly connected digital camera. Hollstrom’s system allows a user to perform camera functions such as capturing, viewing, and deleting images remotely from the phone. Critically, Hollstrom also discloses that after receiving image files, the mobile device is configured to upload them to a designated publishing website. Petitioner argued that Takahashi supplements Hollstrom by explicitly teaching the use of the HTTP protocol for the upload and the inclusion of user information (e.g., a user ID) with the image data, details not specified in Hollstrom.
    • Motivation to Combine: Petitioner argued a POSITA would combine Takahashi's specific teachings with Hollstrom’s broader system to implement a robust and interoperable upload feature. Since HTTP was the standard protocol for web communications, a POSITA implementing Hollstrom’s concept of uploading to a publishing website would naturally and logically turn to a reference like Takahashi for the well-known and efficient method of performing that upload.
    • Expectation of Success: The combination was presented as having a high likelihood of success. Implementing the upload functionality described in Hollstrom using the standard HTTP methods taught by Takahashi would be a routine and predictable task for a software developer skilled in the art.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Ando (JP Application # 2003-46841) and Nozaki (JP Application # 2004-96166). These references were primarily used to supply teachings related to deleting associated files (e.g., thumbnails) via the phone's GUI, addressing specific limitations recited in claims such as 2, 6, 9, 14, and 21-22.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-22 of the ’698 patent as unpatentable.