PTAB

IPR2019-00239

Comcast Cable Communications LLC v. Veveo Inc

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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 describes a search system for devices with overloaded keypads (e.g., a phone keypad where '2' corresponds to 'A', 'B', 'C'). The system creates an index by mapping alphanumeric terms to corresponding numeric keystroke strings, allowing a user to enter an ambiguous query (e.g., "866") to find results like "TOM" or "TON" and incrementally highlighting the matching characters in the displayed results.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5, 6, 8-11, 13, 14, 16-19, 21, 22, and 24 are obvious over Gross in view of Smith.

  • Prior Art Relied Upon: Gross (Application # 2004/0133564) and Smith (Patent 6,529,903).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gross disclosed a system for incremental searching that indexes items based on alphanumeric prefixes and highlights matching search terms in the results. While Gross mentioned use on wireless phones, it did not explicitly detail searching with an overloaded keypad. Smith remedied this by teaching a method for efficient searching on devices with overloaded keypads. Specifically, Smith taught creating a numeric index by translating an alphanumeric index (like Gross's) into numeric keystroke equivalents. The combination, therefore, allegedly taught all limitations of the independent claims, including indexing items by associating them with unresolved keystrokes from an overloaded keypad, receiving an ambiguous query, and incrementally displaying and highlighting results.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Gross's incremental search system with Smith's method for handling overloaded keypad input to improve the speed and efficiency of searching on common devices like wireless phones. Smith explicitly taught improving systems like Gross's by converting alphanumeric indexes to numeric ones, making the combination a predictable application of known techniques to achieve a known goal.
    • Expectation of Success: A POSA would have a clear expectation of success because Smith provided a direct roadmap for translating an alphanumeric index (as taught by Gross) into a numeric index compatible with overloaded keypad input, reducing keystrokes and improving user experience.

Ground 2: Claims 4, 7, 12, 15, 20, and 23 are obvious over Gross in view of Smith and further in view of Sanders.

  • Prior Art Relied Upon: Gross (Application # 2004/0133564), Smith (Patent 6,529,903), and Sanders (Patent 7,885,963).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Gross and Smith combination to address dependent claims related to specific search result ordering and content types. Petitioner asserted that Sanders, which teaches an interactive television network with an electronic program guide (EPG), disclosed the remaining limitations. Specifically, Sanders taught ranking search results by relevancy, such as ordering exact term matches before abbreviation (stemmed) matches, which Petitioner argued satisfied the limitation of claim 4. Sanders also explicitly disclosed searching for television content items, satisfying the limitation of claim 7.
    • Motivation to Combine: A POSA would be motivated to incorporate the teachings of Sanders into the base Gross/Smith system to enhance its functionality. Adding Sanders's relevancy ranking would make the search results more useful by prioritizing exact matches, a known objective in the field. Furthermore, extending the searchable content of the Gross/Smith system to include television content from Sanders's EPG would be a simple and desirable expansion of the system's capabilities.
    • Expectation of Success: A POSA would have an expectation of success in integrating Sanders's features. The techniques for ranking results based on relevance and extending a search system to new data types (like an EPG) were well-understood. Sanders itself taught use with remote controls having few keys, suggesting compatibility with the overloaded keypad environment of Smith.

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 central to Petitioner's argument that the combination of Gross's alphanumeric indexing and Smith's numeric conversion method met the claim limitations.
  • "letters and numbers": Petitioner proposed this phrase be construed as "alphanumeric characters." This construction was based on the specification's description of keys being "overloaded with alpha-numeric characters" and was intended to clarify that the claims do not require both letters and numbers to be present in every search result.
  • "caused said items to be associated...": Petitioner asserted this phrase, which appears in the "determining" step of the claims, should be construed to mean determining the characters that "match a string of unresolved keystrokes directly mapped to the subset." This construction supported the argument that the highlighting taught by Gross was a direct result of determining which characters caused the match with the input query.

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.