PTAB

IPR2020-00460

Amazon v. Hammond Development Intl Inc

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1. Case Identification

2. Patent Overview

  • Title: System for Remotely Executing Applications
  • Brief Description: The ’483 patent discloses a client-server communication system for remotely executing applications. The system comprises client devices connected via a network to an application server which retrieves, executes, and establishes communication sessions for applications stored in a repository, thereby reducing the processing and memory load on the client devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-28 are obvious over Maes.

  • Prior Art Relied Upon: Maes (Patent 6,934,756), which incorporates by reference Maes 2 (International Publication No. WO 00/21035).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Maes, when read with the incorporated Maes 2, discloses every limitation of the challenged claims. Maes described a "distributed conversational system" where a client device (e.g., PDA, smartphone) communicates with a remote "browser server" over a network. This browser server (the application server) retrieves and executes VoiceXML applications from a "presentation server" (the repository) to establish a "conversational session" with the client. Petitioner asserted that Maes’s client acts as a thin-client, providing processing services (e.g., via a CODEC for speech input) to the remotely executed application. Petitioner further contended that storing applications in the memory of Maes’s servers (S1-S3) constituted the claimed "database coupled to the repository," as the ’483 patent describes a database as any form of memory.
    • Key Aspects: This ground asserted that Maes, treated as a single reference including its incorporation of Maes 2, renders all challenged claims obvious without needing modification or combination with other art.

Ground 2: Claims 1-28 are obvious over Maes in view of Bookman.

  • Prior Art Relied Upon: Maes (Patent 6,934,756) and Bookman (Patent 5,761,673).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1. To the extent Maes was found not to teach a repository having access to applications maintained in a coupled database, Petitioner argued that Bookman supplied this teaching. Bookman disclosed a conventional prior art web server environment where a web server (repository) retrieves web pages (applications) from a separate, coupled database. The argument was that Maes already disclosed all other elements of the claims.
    • Motivation to Combine: A POSITA seeking to implement the application storage for Maes's web-based system would have been motivated to look to conventional solutions for accessing applications, such as the database-backed architecture taught by Bookman. This combination was presented as a predictable solution to improve server performance and efficiency, which Bookman taught was an advantage over storing applications in local server memory.
    • Expectation of Success: Because both Maes and Bookman described similar client-server systems for distributing applications over a network, a POSITA would have had a reasonable expectation of success in combining them to use a known database structure for application storage.

Ground 3: Claims 1-28 are obvious over Bharedwaj in view of Salomon.

  • Prior Art Relied Upon: Bharedwaj (International Publication No. WO 01/90915) and Salomon (Application # 2003/0051125).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Bharedwaj disclosed a thin-client system where a client device (e.g., handheld computer) acts as an input/output terminal for applications running on a remote server. Bharedwaj’s server established a communication session upon request from the client. While Bharedwaj taught that applications were downloaded from the Internet, Petitioner argued it lacked a specific disclosure of the repository-database structure. Salomon was introduced to provide this missing element, as it explicitly disclosed a "central site application server" (repository) that stores applications in multiple databases and distributes them over the Internet to remote servers analogous to Bharedwaj's server.
    • Motivation to Combine: A POSITA implementing Bharedwaj's system, which relies on downloading applications, would be motivated to look to references like Salomon to understand how to store and retrieve those applications efficiently. Combining the references would achieve the known benefits taught by Salomon, such as centralized software management, efficient updates, and enhanced security, which are particularly important for a system like Bharedwaj's that interacts with numerous client devices.
    • Expectation of Success: Petitioner asserted a high expectation of success because the combination involved applying a well-known method (using a central repository and database for application distribution) to a similar system to achieve predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including treating Maes and Maes 2 as separate references (Ground 1c) and adding Salesky (Application # 2004/0080504) to the Bharedwaj/Salomon combination for claim 19 (Ground 2b), but these relied on similar combination rationales.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) or §325(d) would be improper. The petition asserted that it is a first-time petitioner against the ’483 patent and is a distinct party from a prior petitioner (Google), making General Plastic factor 1 weigh heavily in favor of institution. Petitioner also argued the grounds presented are simple, were not raised during prosecution or in any prior IPR, and would not place an excessive burden on the Board's resources.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-28 of Patent 9,264,483 as unpatentable.