PTAB

IPR2020-00400

FedEx Corp v. Flectere LLC

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1. Case Identification

2. Patent Overview

  • Title: System and Method for Presenting Information in Accordance with User Preference
  • Brief Description: The ’094 patent describes systems and methods for dynamically presenting information to a user on a workstation. The system formats the information according to a user-specified preference (e.g., "personality traits") to generate and display custom-formatted HTML pages.

3. Grounds for Unpatentability

Ground 1: Obviousness over Isaac and Burkey - Claims 1-24 are obvious over Isaac in view of Burkey.

  • Prior Art Relied Upon: Isaac (Patent 6,632,248) and Burkey (Patent 6,446,076).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Isaac disclosed the core system of claim 1: a server presenting customized HTML documents to a user based on preferences specified through a workstation. Isaac taught that a server receives customization options from a user, stores them, and uses them to form a customized document by "pulling the appropriate news stories out of a database." However, Isaac was not explicit about the structure of its "database or other means" for storing content. Burkey allegedly cured this deficiency by disclosing a system that uses a distinct "content database" to store information and a "user profile database" to store layout preferences and user "personas" (e.g., "home" and "work" contexts). Petitioner asserted that combining Burkey's more detailed database and preference architecture with Isaac's foundational system rendered all limitations of the independent claims obvious. Dependent claims were allegedly met by the combination, such as using cookies for state information (obvious from Isaac) and using "personas" to represent "personality types" (taught by Burkey).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) implementing Isaac's system would have been motivated to incorporate Burkey's teachings for predictable improvements. Specifically, a POSITA would combine Burkey's explicit "content database" with Isaac's system to create a more robust and organized architecture for storing web content. Furthermore, a POSITA would have found it obvious to add Burkey's layout preferences and "personas" to Isaac's system to provide users with more powerful and context-specific customization options, a known goal in web design.
    • Expectation of Success: The combination involved applying known database architectures and preference management techniques (from Burkey) to a known customizable web system (Isaac). A POSITA would have had a reasonable expectation of success because this involved the integration of conventional web technologies to achieve the predictable result of a more versatile and better-structured system.

Ground 2: Obviousness over Isaac, Burkey, and Williams - Claims 8, 14-17, and 20 are obvious over Isaac and Burkey in view of Williams.

  • Prior Art Relied Upon: Isaac (Patent 6,632,248), Burkey (Patent 6,446,076), and Williams (Patent 6,016,484).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 and added Williams to address dependent claims requiring the immediate formatting of information upon a user's selection of a preference, without requiring actuation of a separate "accept" button. Isaac taught providing preferences on a separate customization page where a user clicks "accept" to submit them. Petitioner argued Williams disclosed a user interface for customizing a report where a formatting option (a "report type combobox") was located directly on the report being viewed. Selecting an option from this combobox immediately reformatted the report without requiring a separate confirmation step. This arrangement in Williams, when applied to the Isaac/Burkey combination, allegedly rendered the "immediate formatting" limitations of claims 8 and 20 obvious.
    • Motivation to Combine: A POSITA would combine the teachings of Williams with the Isaac/Burkey system to improve user experience and efficiency. The motivation was to streamline the customization process by eliminating the need for a separate preference page and an extra click on an "accept" button. This was a well-known design trade-off to provide faster, more direct user interaction, especially for a small number of high-level formatting options like those shown in Williams.
    • Expectation of Success: Implementing a known user interface element (an on-page dropdown for immediate updates, as in Williams) into a customizable webpage (the Isaac/Burkey system) was a straightforward design choice. A POSITA would have reasonably expected this combination to predictably result in a more streamlined and responsive user interface.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-24 of the ’094 patent as unpatentable under 35 U.S.C. §103.