PTAB

IPR2019-00237

Comcast Cable Communications LLC v. Veveo Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Method And System For Dynamically Processing Ambiguous, Reduced Text Search Queries And Highlighting Results Thereof
  • Brief Description: The ’011 patent discloses a method for processing search queries entered on a device with an "overloaded" keypad, where single keys correspond to multiple characters. The system uses an index to incrementally find and display search results as a user types, highlighting the characters in the results that match the ambiguous keystroke input.

3. Grounds for Unpatentability

Ground 1: Obviousness over Howard, King, and Payne - Claims 1-3, 5-11, 13-19, and 21-24

  • Prior Art Relied Upon: Howard (Application # 2007/0027848), King (Patent 6,011,554), and Payne (Patent 6,370,518).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Howard taught the foundational system: a mobile device using an overloaded keypad for incremental searching that highlights results. However, Howard's method of generating an inefficient "expanded lookup set" for all possible character combinations was a significant drawback. King disclosed a more efficient tree data structure that serves as an index to search based on ambiguous keystrokes directly, avoiding the need to expand the query. Separately, Payne taught a superior method of incrementally highlighting search results by bolding the specific characters that matched the keystroke sequence, providing clearer user feedback than Howard's simple box highlighting. The proposed combination replaces Howard's inefficient search method with King's efficient tree index and substitutes Howard's basic highlighting with Payne's more informative, incremental highlighting.
    • Motivation to Combine: A POSITA would combine Howard and King to improve the search speed and efficiency of Howard's system, a well-known design goal in the art. The POSITA would further incorporate Payne’s incremental highlighting to provide better visual feedback to the user, another common objective in user interface design, thereby helping users understand why certain results were returned.
    • Expectation of Success: The combination involved applying known and compatible techniques to an existing system, all within the predictable field of search interfaces for mobile devices. A POSITA would have reasonably expected success because the references addressed the same technical problem.

Ground 2: Obviousness over Howard, King, Payne, and Sanders - Claims 4, 12, and 20

  • Prior Art Relied Upon: Howard (Application # 2007/0027848), King (Patent 6,011,554), Payne (Patent 6,370,518), and Sanders (Patent 7,885,963).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring displayed items to be ordered such that "term matches" are shown before "abbreviation matches." The base combination of Howard, King, and Payne provided the core search system. Sanders was introduced because it taught a system that used stemming to find abbreviation matches and, crucially, a relevance ranking method that explicitly displayed exact term matches before these stemmed, less-relevant results.
    • Motivation to Combine: A POSITA would incorporate Sanders’s ranking technique into the primary Howard/King/Payne combination to improve the quality and relevance of search results. While stemming (as taught by Sanders) increases the number of potential hits, it can also introduce irrelevant results; Sanders’s ranking method was a known and logical solution to mitigate this disadvantage.
    • Expectation of Success: Integrating a known result-ranking technique into an existing search system was a predictable and routine task for a POSITA seeking to enhance user experience.

Ground 3: Obviousness over Howard, King, Payne, and Gross - Claims 5, 13, and 21

  • Prior Art Relied Upon: Howard (Application # 2007/0027848), King (Patent 6,011,554), Payne (Patent 6,370,518), and Gross (Application # 2004/0133564).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring the search query to be processed by a remote server system. While the base combination described a client-side system, Gross taught a search architecture that could operate on a client or, alternatively, use a server-based search application to perform the search remotely.
    • Motivation to Combine: A POSITA would be motivated to move search processing to a remote server, as taught by Gross, to leverage a server's greater processing power and memory. This modification would allow for larger databases and faster searches while conserving critical resources like battery and memory on the mobile client device, which were well-understood design constraints.
    • Expectation of Success: Client-server architectures were a well-known paradigm. A POSITA would have reasonably expected success in modifying the combined system to offload search processing to a server, as this was a common and predictable engineering design choice for mobile applications.

4. Key Claim Construction Positions

  • "directly mapped": Petitioner argued this term should be construed as "each alphanumeric character of a search query prefix substring associated with an item is matched with its corresponding numeric key equivalent on an overloaded keypad." This construction, which the PTAB adopted in a related case, was central to Petitioner's argument for how King’s efficient tree index met the claim language.
  • "letters and numbers": Petitioner proposed construing this phrase as "alphanumeric characters." This construction aligns with the patent's specification and prevents an improperly narrow reading that would require both letters and numbers to be present in the information associated with every indexed item.
  • "caused said items to be associated...": Petitioner argued this phrase should be construed to mean determining the characters that "match a string of unresolved keystrokes directly mapped to the subset." This construction links the "cause" of the association to the fundamental matching of alphanumeric characters to keystrokes that occurs during the indexing process.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-24 of the ’011 patent as unpatentable.