PTAB

IPR2019-01278

Lenovo Holding Co Inc v. DoDots Licensing Solutions LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Methods for Creating and Authoring Internet Content Using Application Media Packages
  • Brief Description: The ’083 patent relates to a system for distributing and displaying internet content using self-contained application packages termed "networked information monitors" (NIMs). The technology purports to give content providers greater control over the graphical user interface (GUI) and content presentation than is possible when content is displayed within the frame of a standard web browser.

3. Grounds for Unpatentability

Ground 1: Obviousness over Castanet System References - Claims 1-16 are obvious over Hoff in view of Berg.

  • Prior Art Relied Upon: Hoff (Patent 5,919,247) and Berg (a 1998 Dr. Dobb's Journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hoff disclosed the fundamental client-server architecture (the Marimba Castanet platform) for distributing software applications, called "channels," from a server ("transmitter") to a client ("tuner"). Berg was argued to provide a specific, working example of a Castanet channel that generates its own GUI independent of a web browser, fetches content from a predefined URL, and displays that content within its own frame. Petitioner asserted that Berg's channel, when distributed using Hoff's system, met the limitations of a "networked information monitor template" as recited in independent claims 1 and 9. The combination taught a downloadable template (the channel) that defines a GUI lacking general web navigation controls, contains a reference to a content location, and includes instructions to fetch and display the content. For dependent claims, Petitioner argued that having multiple channels (as taught by Hoff) and user controls (like a close button, taught by Berg) were obvious extensions.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hoff and Berg because Berg explicitly described its channel application as being designed for implementation on Marimba's Castanet system, the very platform detailed in Hoff. The references were therefore directly complementary.
    • Expectation of Success: Petitioner asserted a high expectation of success because Berg provided a concrete software example purpose-built for the foundational architecture taught by Hoff, demonstrating the combination's feasibility and predictability.

Ground 2: Obviousness over Detachable Java Applet References - Claims 1-16 are obvious over Razavi in view of Anderson.

  • Prior Art Relied Upon: Razavi (Patent 6,401,134) and Anderson (Patent 5,999,941).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Anderson disclosed a conventional Java applet, such as a stock ticker, that retrieves data from a server and displays it within a GUI that is typically rendered inside a browser window. Razavi was argued to teach a generic method for "detaching" such Java applets from the constraints of the browser, allowing them to run as standalone applications with their own independent GUI directly on the user's desktop. Petitioner contended that combining Anderson's functional applet with Razavi's detaching technology would result in the claimed invention. The resulting detached applet would function as a "networked information monitor" that generates its own GUI (lacking browser navigation controls), fetches content from a specific network location (the stock data server), and displays it, thereby meeting the limitations of independent claims 1 and 9.
    • Motivation to Combine: A POSITA would be motivated to combine the references to enhance usability. Applying Razavi's detaching method to Anderson's stock applet would allow a user to keep the stock ticker visible in a discrete desktop window while using the main web browser for other tasks. This represented a clear and desirable functional improvement over a browser-constrained applet.
    • Expectation of Success: Petitioner argued for a reasonable expectation of success because both references involved standard Java applets. Razavi's method was presented as a generic technique applicable to such applets, making its application to the applet in Anderson a straightforward and predictable modification.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-16 of the ’083 patent as unpatentable.