PTAB

IPR2019-01279

Lenovo Holding Co Inc v. DoDots Licensing Solutions LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Displaying Time-Varying Internet Based Data Using Application Media Packages
  • Brief Description: The ’407 patent describes a software component for accessing and displaying time-varying internet content. The system uses a "Networked Information Monitor" (NIM) template to render a graphical user interface (GUI) that is separate from a conventional web browser, allowing content providers to control the frame and user controls for displaying their content.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1, 9-13, 21-24 over Hoff, Berg, and Nazem or Applicant Admitted Prior Art (APA)

  • Prior Art Relied Upon: Hoff (Patent 5,919,247), Berg (Dr. Dobb’s Journal, Jan. 1998), and Nazem (Patent 5,983,227) or APA.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hoff and Berg collectively disclose Marimba’s Castanet system, where a client-side "tuner" downloads standalone software "channels" from a server. These channels, as described by Berg, are Java applications that generate their own fully configurable GUI, which opens as a distinct window separate from any web browser. Berg’s exemplary channel fetches and displays webpage content within its GUI. Nazem and APA teach that it was well-known for webpages to include time-varying content, such as stock quotes and news headlines. The combination thus teaches a client device that stores a template (the channel), which defines a GUI lacking network navigation controls and is presented outside of any other application’s GUI, to display time-varying content from a specified network location.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Hoff and Berg because Berg’s channel application was expressly designed to run on a push-technology system like that described in Hoff. A POSITA would have been motivated to modify Berg’s channel to display time-varying content as taught by Nazem or APA to provide users with up-to-date information rather than static content.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Berg explicitly notes its channel can be implemented on a system like Hoff's. Modifying the application to point to a URL with time-varying content was a simple and predictable alteration.

Ground 2: Obviousness of Claims 8 and 20 over Hoff, Berg, Nazem (or APA), and Fortin

  • Prior Art Relied Upon: Hoff (Patent 5,919,247), Berg (Dr. Dobb’s Journal, Jan. 1998), Nazem (Patent 5,983,227) or APA, and Fortin (Application # 2002/0023110).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Fortin to the combination of Ground 1 to address the limitations of claims 8 and 20, which require the NIM template to include a markup language file. Petitioner asserted that Fortin teaches using a markup language file with a Java application to generate more complex and advanced GUIs, such as those with multiple layers.
    • Motivation to Combine: A POSITA would combine Fortin's teachings with the Java-based channel application of Berg to provide more advanced graphical features. Berg itself contemplated adding more advanced features to its GUI, and using a markup language file as taught by Fortin was a known method for achieving this.
    • Expectation of Success: Success was predictable because both the Berg channel and the Fortin applet are Java-based, making the integration of a markup language file for GUI generation a straightforward task for a POSITA.

Ground 3: Obviousness of Claims 1, 9-13, 21-24 over Razavi and 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 Razavi discloses "detachable" Java applets capable of running in a GUI that is separate from and outside the constraints of the web browser that launched them. Anderson discloses a conventional Java applet that retrieves and displays time-varying content (stock prices) within a GUI. Petitioner contended that the combination of Anderson's content-retrieving applet with Razavi's "detachable" functionality results in an application that presents time-varying content in a GUI that is "outside of and separate from" the browser GUI, meeting the key limitations of the independent claims.
    • Motivation to Combine: A POSITA would be motivated to apply Razavi's detachable functionality to Anderson’s stock-quoting applet. This would improve usability by allowing the user to keep the stock price GUI visible on the desktop while navigating to different pages in the main browser window.
    • Expectation of Success: A POSITA would reasonably expect success in combining these teachings because both references describe Java applets, and implementing the detachability function described in Razavi within the Anderson applet would be a predictable modification.

Ground 4: Obviousness of Claims 8 and 20 over Razavi, Anderson, and Fortin

  • Prior Art Relied Upon: Razavi (Patent 6,401,134), Anderson (Patent 5,999,941), and Fortin (Application # 2002/0023110).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Fortin to the combination of Ground 3 to teach the "markup language file" limitation of claims 8 and 20. As in Ground 2, Fortin discloses using a markup language file to generate advanced GUIs for Java applications.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Fortin’s teachings into the combined Razavi/Anderson applet to provide more sophisticated graphical features and dynamic menus, enhancing the user experience beyond a simple data display.
    • Expectation of Success: Given that the applets in Razavi and Anderson are Java-based, a POSITA would have reasonably expected to successfully integrate a markup language file for GUI generation as taught by Fortin.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the claim term "outside of and separate from any [GUI] of any other application" based on the patent’s prosecution history.
  • Proposed Construction: "so that the viewer [GUI] is distinct from and not presented within the frame of any other GUI generated by another application."
  • Rationale: During prosecution, the applicant distinguished the invention from the Doyle prior art by arguing Doyle's GUI was presented within the GUI of a web browser. Petitioner contended this history establishes that the claimed GUI must not be displayed within the boundaries of any other application’s GUI (e.g., a browser), a key element for its arguments based on the standalone applications of Berg and the "detachable" applets of Razavi.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 8-13, and 20-24 of the ’407 patent as unpatentable.