PTAB
IPR2019-00290
Comcast Cable Communications LLC v. Veveo Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2019-00290
- Patent #: 7,937,394
- Filed: November 12, 2018
- Petitioner(s): Comcast Cable Communications, LLC
- Patent Owner(s): Veveo, Inc.
- Challenged Claims: 1-11
2. Patent Overview
- Title: Method and System for Dynamically Processing Ambiguous, Reduced Text Search Queries and Highlighting Results Thereof
- Brief Description: The ’394 patent discloses a method for processing ambiguous search queries entered on a device with an overloaded keypad, such as a multi-tap phone keypad where one key corresponds to multiple characters. The system incrementally retrieves and displays search results as a user types, highlighting the characters in the results that match the ambiguous keystroke sequence.
3. Grounds for Unpatentability
Ground 1: Claims 1, 2, 4-6, and 8-11 are obvious over Howard in view of King and Payne.
- 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 the combination of these references teaches all limitations of the independent claims. Howard was asserted to teach the foundational system: a search function on a mobile device using an overloaded keypad that performs incremental searching and highlights matching results with a box. However, Howard used an inefficient "expanded lookup set" for indexing. King was asserted to teach a more efficient tree-based data structure that functions as an index, directly mapping keystroke sequences to items without requiring an expanded lookup set. Payne was asserted to teach an alternative or supplemental method of incremental highlighting using bold text as a "visual feedback indicator" to show the user which characters correspond to the entered keystrokes.
- Motivation to Combine: A POSITA would combine King with Howard to improve the search system's efficiency and scalability by replacing Howard's inefficient indexing method with King's well-understood and superior tree-based index. A POSITA would also be motivated to incorporate Payne’s incremental bold-text highlighting into the combined Howard/King system to provide clearer, more effective visual feedback to the user, which was a known design goal for such interfaces.
- Expectation of Success: A POSITA would have a reasonable expectation of success because all three references address the same technical problem of ambiguous text entry. Combining King's superior index and Payne's enhanced highlighting were characterized as predictable solutions using known techniques to improve a prior art system (Howard), yielding the expected benefits of increased speed and improved user experience.
Ground 2: Claim 3 is obvious over Howard, King, and Payne, further in view of Sanders.
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 builds upon the combination in Ground 1 to address dependent claim 3, which requires ordering search results to display full-word matches before abbreviated matches. Petitioner argued that Sanders teaches this exact functionality, disclosing a search system that uses stemming (a form of abbreviation) and a relevance ranker to order results so that exact matches are displayed before less-relevant stemmed matches.
- Motivation to Combine: A POSITA would combine Sanders' ranking and stemming techniques with the Howard/King/Payne system to improve the quality and relevance of search results. This combination would allow the system to return a broader set of results (via stemming) while still prioritizing the most relevant, exact matches, a common objective in search system design.
- Expectation of Success: Success would be expected, as implementing a known ranking method (from Sanders) to manage results from a known search-broadening technique (stemming) was a straightforward and predictable modification.
Additional Grounds: Petitioner asserted additional obviousness challenges for remaining dependent claims by adding a single, targeted prior art reference to the primary Howard, King, and Payne combination. These included:
- Claim 4 as obvious further in view of Gross (Application # 2004/0133564) to teach processing the search query on a remote server.
- Claim 7 as obvious further in view of Weeren (Patent 6,501,956) to teach the claimed device being a desk phone.
- Claims 8 and 9 as obvious further in view of Robarts (Application # 2005/0278741) to teach the device being a television remote control and the searched items being television content.
4. Key Claim Construction Positions
Petitioner argued for specific constructions of several key terms, asserting they were critical to the invalidity analysis.
- "directly mapped": Petitioner proposed this term 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 argued to be consistent with a PTAB decision on a related patent and the ’394 patent’s specification, which describes a many-to-many mapping from alphanumeric terms to numeric strings.
- "letters and numbers": Petitioner argued this phrase should be construed as "alphanumeric characters." This was based on the specification's use of "alpha-numeric" and the fact that a POSITA would understand the term to mean characters that could be either letters or numbers, not necessarily both in every instance.
- "caused the items to be associated...": Petitioner proposed this lengthy phrase be construed as determining the characters that "match a string of unresolved keystrokes directly mapped to the subset." The argument was that in the context of the patent, the "cause" of the association is the underlying match between the alphanumeric characters of an item and the numeric keystroke equivalents.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-11 of Patent 7,937,394 as unpatentable.
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