PTAB

IPR2019-00238

Comcast Cable Communications LLC v. Veveo Inc

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Key Events
Petition
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 devices with overloaded keypads (e.g., a T9-style telephone keypad) where a single key corresponds to multiple characters. The system incrementally retrieves and displays search results as a user types, highlighting the characters in the results that correspond to the ambiguous keystroke entries.

3. Grounds for Unpatentability

Ground 1: Obviousness over Zigmond, Smith, and Payne - Claims 1-2, 5-10, 13-18, and 21-24 are obvious over Zigmond in view of Smith and Payne.

  • Prior Art Relied Upon: Zigmond (Application # 2005/0256846), Smith (Patent 6,529,903), and Payne (Patent 6,370,518).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary references collectively teach every limitation of the challenged claims. Zigmond taught a client-server system for incremental searching of indexed items (e.g., TV program titles) that are mapped to alphanumeric prefixes. Smith taught using a more efficient numeric index for systems with overloaded keypads, where content is mapped to numeric strings corresponding to the keypad, and further taught converting an alphanumeric index to such a numeric index. Payne taught an incremental search system using an overloaded keypad that highlights the characters in the search results that correspond to the user's numeric key entries to provide visual feedback.
    • Motivation to Combine: A POSITA would combine Zigmond’s incremental search system with Smith’s numeric indexing to improve search efficiency for devices with overloaded keypads, which Zigmond already disclosed as a possible input device. This combination would be a mere application of Smith’s known technique to a system (Zigmond) ready for improvement. Subsequently, a POSITA would incorporate Payne’s highlighting feature into the combined Zigmond/Smith system to improve user experience by visually indicating how results match the ambiguous input, a known goal for search interfaces.
    • Expectation of Success: A POSITA would have had a high expectation of success because combining these elements involved the application of known, predictable techniques. Both Zigmond and Smith taught indexed search systems, making the substitution of a numeric index for an alphanumeric one straightforward. Adding a highlighting feature as taught by Payne was a well-known method for improving search result usability.

Ground 2: Obviousness over Zigmond, Smith, Payne, and Sanders - Claims 3-4, 11-12, and 19-20 are obvious over Zigmond, Smith, and Payne in further view of Sanders.

  • Prior Art Relied Upon: Zigmond (Application # 2005/0256846), Smith (Patent 6,529,903), Payne (Patent 6,370,518), and Sanders (Patent 7,885,963).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination in Ground 1 to address dependent claims reciting specific criteria for ordering search results. The base combination from Ground 1 teaches ordering results alphabetically. Sanders taught an incremental search system with more advanced methods for ranking and filtering results, such as by temporal relevance, popularity, and personal preferences. Sanders also taught ordering results such that exact term matches are displayed before abbreviation matches (i.e., matches found via stemming).
    • Motivation to Combine: The system of Zigmond/Smith/Payne produced a list of search results that were only ordered alphabetically. A POSITA would be motivated to incorporate the more sophisticated ranking and ordering techniques from Sanders to provide a user with more useful and flexible ways to sort search results. This would be a predictable improvement to the base system, as providing better result ranking is a common design goal.
    • Expectation of Success: There was a reasonable expectation of success because adapting known ranking and filtering techniques from one search system (Sanders) to another (Zigmond/Smith/Payne) was a straightforward modification for a POSITA, especially since all references were directed to incremental search systems.

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 was based on a parallel construction adopted by the PTAB in a previous IPR invalidating a related patent.
  • "letters and numbers": Petitioner argued this phrase should be construed as "alphanumeric characters." This was based on the specification's use of "alpha-numeric characters" to describe the overloaded keys and the fact that not all indexed items contain both letters and numbers.
  • "caused said items to be associated with the strings of one or more unresolved keystrokes...": Petitioner argued this phrase, which appears in a "determining" step, should be construed as determining the characters that "match a string of unresolved keystrokes directly mapped to the subset." This construction was based on the specification's description that the system's direct mapping is the match between alphanumeric terms and their numeric equivalents.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-24 of the ’011 patent as unpatentable under 35 U.S.C. §103.