PTAB

IPR2019-01363

Sling TV LLC v. Uniloc 2017 LLC

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1. Case Identification

2. Patent Overview

  • Title: Providing audio and visual presentations via a computer network
  • Brief Description: The ’273 patent discloses a method and system for aggregating three distinct collections of presentations (content) from various sources, including content identified via standardized feeds like Really Simple Syndication (RSS), and delivering them for display on a single, common webpage.

3. Grounds for Unpatentability

Ground 1: Obviousness over Li and POSA Knowledge - Claims 1-3 are obvious over Li in view of the knowledge of a Person of Ordinary Skill in the Art (POSA).

  • Prior Art Relied Upon: Li (Application # 2008/0256443) and the general knowledge of a POSA regarding internet and feed technologies.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Li discloses a system for aggregating and displaying content on a personalized webpage from mixed sources, which maps directly to the claimed invention. Li’s system aggregates a “first collection” of content (e.g., data files like music or videos), a “second collection” identified via an RSS feed, and a “third collection” from another source (e.g., another RSS feed or a regular website). The portal server in Li performs the claimed steps of storing data representing these collections and accessing the feeds. Petitioner contended that the key limitation “wherein each of the feeds… includes no data representing content of the second collection” is inherently met by Li’s disclosure of standard RSS feeds, as an RSS feed address points to a channel of content, not the content data itself.
    • Motivation to Combine: The petition asserted that to the extent Li does not explicitly disclose automatically and periodically accessing feeds, a POSA would have been motivated to implement this functionality. Li’s background section explicitly describes that RSS aggregators periodically check for new content. Therefore, a POSA would have found it obvious to apply this conventional and intended function of an RSS aggregator to the aggregator system disclosed by Li.
    • Expectation of Success: A POSA would have a high expectation of success in configuring Li's RSS aggregator to poll for updates periodically, as this was a well-known, standardized feature of such systems used for its intended purpose.

Ground 2: Obviousness over Li in view of Motte - Claims 1-3 are obvious over Li in view of Motte.

  • Prior Art Relied Upon: Li (Application # 2008/0256443) and Motte (Application # 2008/0071929).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative, asserting that Li teaches the core system of aggregating three distinct content collections as argued in Ground 1. Motte was introduced to provide explicit teachings and clear visual examples of aggregating diverse content types (e.g., text feeds, image feeds, blogs, video, audio) into distinct modules on a single, modular webpage. Petitioner argued that Motte’s screenshots confirm that bringing different collections of presentations together in visual juxtaposition on a common webpage was a known technique. Motte’s disclosure of a webpage comprising modules for RSS feeds, user blogs, and photos/videos was argued to directly correspond to the three collections aggregated by Li.
    • Motivation to Combine: A POSA would combine the teachings of Li and Motte because they are in the same technical field and solve the same problem of aggregating and presenting content to a user. A POSA would be motivated to apply Motte’s modular and visually organized webpage layout to Li’s content aggregation system to improve the user interface’s readability and flexibility. This combination represents the application of a known user interface technique (Motte) to a similar system (Li) to yield predictable results.
    • Expectation of Success: The combination was asserted to be a predictable integration of a known user interface design with a content aggregation backend. A POSA would have reasonably expected success in using Motte’s established layout techniques to display the content aggregated by Li’s system.

4. Key Claim Construction Positions

  • “aggregating each of the first, identified second, and third collections of presentations for delivery via… a common web page”: Petitioner proposed this term be construed as “bringing together in visual juxtaposition each of the first, identified second, and third collections of presentations for delivery via the computer network using a common web page.” This construction was based on the patent’s figures and the ordinary meaning of “aggregate” in the context of web design, and it was critical for leveraging the visual layouts shown in the Motte reference.
  • “storing feed data that represents a collection of one or more feeds… wherein each of the feeds identifies a corresponding second collection… and includes no data representing content of the second collection”: Petitioner argued that this language, added during prosecution, describes the conventional functionality of an RSS feed. A POSA would understand the “feed data” to be the address (e.g., URL) of the RSS feed. This address itself contains no content but merely identifies a channel where content items can be found. This construction was central to arguing that Li’s disclosure of a standard RSS aggregator inherently meets this limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-3 of the ’273 patent as unpatentable under 35 U.S.C. §103.