PTAB

IPR2019-00988

Lenovo Holding Co Inc v. DoDots Licensing Solutions LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Accessing and Displaying Network Content
  • Brief Description: The ’545 patent describes a method for aggregating and presenting network content in a configurable graphical user interface (GUI). The technology allows content providers to develop "Networked Information Monitors" (NIMs), which are defined by a template and presented as a fully configurable frame, purportedly to give providers more control over the user experience than is possible within a conventional web browser.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 10, and 14 are obvious over Hoff in view of Berg.

  • Prior Art Relied Upon: Hoff (Patent 5,919,247) and Berg (Dr. Dobb's Journal, Jan. 1, 1998).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Hoff and Berg teaches all limitations of independent claim 1. Hoff disclosed the Marimba Castanet system, a client-server architecture for distributing software applications, called "channels," from a server ("transmitter") to a client device ("tuner"). Berg described an exemplary Castanet channel application built using Java. This channel, when executed, created its own standalone GUI window on the user's display, distinct from any browser. The GUI contained controls (e.g., a drop-down menu) to select a URL, fetch the corresponding webpage over the internet, and display it within the GUI. Petitioner contended this system met the key limitations of receiving a template (the channel), defining a viewer GUI, and presenting that GUI "separate from and outside of any other [GUI]" (such as a browser) that might have initiated the request.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hoff and Berg because Hoff provided a general-purpose system for distributing any software application, and Berg described a specific, exemplary application expressly designed to run on the Castanet system.
    • Expectation of Success: A POSITA would have a high expectation of success because Berg’s channel was specifically created for a system like the one described in Hoff, ensuring compatibility.

Ground 2: Claims 1, 6-7, 10, and 12-15 are obvious over Razavi in view of Banthia.

  • Prior Art Relied Upon: Razavi (Patent 6,401,134) and Banthia (Patent 5,922,044).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted this combination, based on detachable Java applets, also rendered claim 1 obvious. Razavi taught a system for detaching a Java applet from the constraints of the application that spawned it (e.g., a web browser), allowing the applet's GUI to run as an independent window on the desktop. Razavi’s example was a "Jukebox" applet that could stream audio content from a network server. Banthia taught a system with multiple Java applets ("controlling" and "display" applets) that could be "torn off" from a browser window, communicate with each other, and be periodically updated with new data from a server. Petitioner argued that Razavi’s detachable applet, running on a conventional client device like that shown in Banthia, met the limitations of claim 1, including presenting a GUI "separate from and outside of" a browser.
    • Motivation to Combine: A POSITA would have been motivated to run the detachable applets of Razavi on the conventional client architecture of Banthia. For dependent claims, a POSITA would add Banthia's inter-applet communication and periodic update features to Razavi's applets to enhance functionality, such as allowing a Jukebox applet to communicate with other media player applets or to check for new available audio content.
    • Expectation of Success: Because both references described similar systems involving downloadable Java applets running on a client device, a POSITA would have reasonably expected that the features could be successfully combined.

  • Additional Grounds: Petitioner asserted additional obviousness challenges that built upon these two core combinations. Other grounds added references like Berry (Patent 5,586,244) and Dang (Patent 7,216,300) to teach well-known GUI controls (e.g., resizing, moving) and the use of XML. Cordell (Patent 5,778,372) was added to teach presenting content overlaid on a background image.

4. Key Claim Construction Positions

  • Term: "separate from and outside of any other [GUI]" (Claim 1)
  • Proposed Construction: Petitioner argued this term requires the viewer GUI to meet two conditions: (1) it must be a distinct GUI from the "other GUI" (i.e., "separate from"), and (2) it must not be presented within the frame of the "other GUI" (i.e., "outside of").
  • Rationale: This construction was based on the prosecution history of parent applications, where the applicant distinguished the invention from prior art (e.g., Doyle) that disclosed a distinct application GUI displayed within the window of a web browser. Petitioner argued this construction was critical and that the standalone application windows taught by Berg and the detached applets taught by Razavi met this "separate and outside" limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10 and 12-15 of Patent 9,369,545 as unpatentable.