PTAB

IPR2019-00292

Comcast Cable Communications LLC v. Veveo Inc

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 ’394 patent discloses a method for processing ambiguous search queries entered on a device with a keypad having overloaded keys (e.g., a T9-style telephone keypad). The system creates an index mapping alphanumeric terms to numeric strings, allows for incremental searching, and highlights the matching characters in the displayed results.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, 5, 6, 10, and 11 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 taught an incremental search system that pre-indexed words and word prefixes, retrieved results as a user typed, and highlighted matching search terms. However, Gross did not explicitly disclose using an overloaded keypad. Smith remedied this by teaching a system for processing ambiguous queries from an overloaded keypad, which involved translating a conventional alphanumeric index (like that in Gross) into an efficient numeric index based on the keypad layout. Smith’s system directly mapped content items to numeric key strings.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Gross’s search system with Smith’s efficient input and indexing method to improve the user experience for searching on devices with overloaded keypads, such as the wireless phones contemplated by Gross. The combination would predictably reduce the number of keystrokes required, improve search efficiency, and enhance usability, which were known goals in the art.
    • Expectation of Success: A POSA would have a high expectation of success, as Smith explicitly taught how to convert an alphanumeric index into a numeric index, making it a straightforward application of a known technique to improve a known system.

Ground 2: Claims 3, 8, and 9 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 built upon the Gross/Smith combination by adding teachings from Sanders. Petitioner asserted Sanders disclosed several features relevant to the dependent claims. For claim 3, Sanders taught ordering search results by relevance, specifically ranking exact matches higher than abbreviation matches (i.e., stemmed words). For claim 8, Sanders disclosed using a remote control with limited input capability for an interactive television system. For claim 9, Sanders disclosed an electronic program guide for searching television content items.
    • Motivation to Combine: A POSA would be motivated to incorporate Sanders's features into the Gross/Smith system to enhance its utility. Ranking results by relevance is a well-known method for improving search result presentation. Applying the search system to television remote controls and content was a natural and obvious extension, particularly as Gross already mentioned interactive televisions.
    • Expectation of Success: The integration of known features like result ranking and application to television systems would have been a simple exercise for a POSA with a predictable outcome.

Ground 3: Claim 7 is obvious over Gross in view of Smith and further in view of Weeren.

  • Prior Art Relied Upon: Gross (Application # 2004/0133564), Smith (Patent 6,529,903), and Weeren (Patent 6,501,956).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Weeren to the Gross/Smith combination to address dependent claim 7, which requires the user device to be a desk phone. Weeren taught an information retrieval system that could be accessed by either a wireless phone or a desk phone, teaching that a desk phone was a known alternative for accessing such search services.
    • Motivation to Combine: A POSA would have been motivated to adapt the Gross/Smith system to operate with a desk phone, as taught by Weeren, to beneficially expand the number of devices that could access the search services.
    • Expectation of Success: A POSA would have a reasonable expectation of success because modifying the system to work on a desk phone was a simple software modification, representing the mere application of a known technique (using a desk phone as a client) to an existing system.

4. Key Claim Construction Positions

  • "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." Petitioner argued this construction was consistent with the specification and parallel to a construction adopted by the PTAB in an IPR for a related patent.
  • "letters and numbers": Petitioner proposed construing this phrase as "alphanumeric characters." This was argued to align with the specification’s terminology and clarify that the information does not need to contain both letters and numbers, but rather characters that can be either.
  • "caused said items to be associated...": Petitioner proposed this phrase be construed as determining the characters that "match a string of unresolved keystrokes directly mapped to the subset." Petitioner contended this "determination" occurs during the creation of the index, where the alphanumeric characters are matched to their numeric equivalents.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-11 of the ’394 patent as unpatentable.