PTAB

IPR2020-00006

Unified Patents LLC v. Cedar Lane Technologies Inc

Log In

1. Case Identification

2. Patent Overview

  • Title: User Interface for Simultaneous Management of Owned and Unowned Inventory
  • Brief Description: The ’177 patent relates to a computer user interface for managing an inventory of items, such as a digital music playlist. The interface displays a list of items and provides a visual indication for each item to show whether it is owned or unowned by the user.

3. Grounds for Unpatentability

Ground 1: Claims 1, 10, 12-13, and 15-16 are obvious over Looney, DeMartin, and Cluts.

  • Prior Art Relied Upon: Looney (Patent 5,969,283), DeMartin (Patent 6,226,672), and Cluts (Patent 5,616,876).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Looney, teaches a user interface for managing a music library that explicitly includes an "ownership column." This column displays "Yes" or "No" to indicate whether a song in a master list is owned by the user. Petitioner asserted that DeMartin and Cluts both teach systems for creating and transferring playlists over a network, such as the Internet. The combination of Looney's ownership-indication interface with the network-transferred playlists taught by DeMartin and Cluts allegedly renders all limitations of independent claim 1 obvious.
    • Motivation to Combine: A POSITA would combine Looney with the teachings of DeMartin or Cluts to improve Looney’s system. Instead of requiring a user to create playlists locally, the combination would allow the system to receive and manage pre-made playlists transferred over a network, which was a known technique for enhancing digital music systems and improving user convenience.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Looney already taught receiving and storing individual music files over a network. Applying the known technique of transferring a playlist file, as taught by DeMartin and Cluts, to Looney's system would be a predictable integration to manage a group of those files.

Ground 2: Claims 2-7, 9, 11, 17-19, 21-22, and 24-25 are obvious over Looney, DeMartin, Cluts, and Wiser.

  • Prior Art Relied Upon: Looney (Patent 5,969,283), DeMartin (Patent 6,226,672), Cluts (Patent 5,616,876), and Wiser (Patent 6,385,596).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Wiser to the base combination from Ground 1 to address dependent claims related to purchasing unowned items. Petitioner argued that Wiser teaches a secure online music distribution system where a media player interface includes a "Buy Download" button. Selecting this button initiates the purchase and download of an unowned song from a music distribution center over the Internet. This functionality maps directly to limitations in claims requiring the ability to initiate a purchase of an unowned item from the playlist (claim 2), provide a link to an online vendor (claim 4), and download the purchased music (claim 5).
    • Motivation to Combine: A POSITA would be motivated to incorporate the purchasing features of Wiser into the Looney system to create a more integrated and commercially useful product. This would allow a user to act immediately on the ownership information provided by Looney’s interface by purchasing desired unowned music directly, a logical and predictable improvement.
    • Expectation of Success: Success would be expected because Looney already disclosed a system where users could order music over the Internet from a service provider. Wiser provided a specific and well-understood implementation for this functionality (e.g., a "Buy" button), making its integration into the Looney interface a combination of known elements to achieve a predictable result.

  • Additional Grounds: Petitioner asserted further obviousness challenges. Ground 3 added Burke (Patent 6,032,162) to the combination of Ground 2, arguing Burke taught using electronic mail as a known and equivalent alternative to FTP for transferring playlists online. Ground 4 added Morioka (European Application # EP0427264A2) to the base combination of Ground 1, arguing Morioka taught replacing text-based status indicators (like Looney's "Yes"/"No") with pictorial status icons to improve user-friendliness, thereby rendering claim 23 obvious.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate because the ’177 patent had not been challenged in any prior IPR petition. Therefore, petitioner contended that none of the discretionary institution factors weigh in favor of denying institution of the review.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-26 of the ’177 patent as unpatentable under §103.