PTAB

IPR2021-00987

Snap Inc v. Palo Alto Research Center LLC

Key Events

Petition

petition Intelligence

Title: Delivering Context-Based Content
Brief Description: The ’599 patent describes techniques for presenting content to a user based on contextual information. The disclosed system processes contextual data to determine a user's current activity or context and, if that context satisfies a predefined trigger condition, presents relevant content to the user.

Prior Art Relied Upon: Rosenberg (Patent 7,577,522).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Rosenberg discloses every element of the challenged claims. Rosenberg teaches a method for delivering "personal digital reminders" to a user on a portable device when the user satisfies a location-based "trigger event." This corresponds to the ’599 patent’s "context-based content." Rosenberg’s reminders function as "content packages" that include a "content piece" (the reminder text, image, etc.) and a set of rules, such as a "trigger condition" (e.g., entering or exiting a defined geographic area) and an "expected response" (e.g., an option to "defer" the reminder). The system receives contextual information (user location from a sensor), processes it to determine the user's context relative to a trigger area, and presents the content when the condition is met, directly mapping to the method of independent claim 1.
- Key Aspects: Petitioner contended that Rosenberg’s detailed description of a location-aware reminder system, including its data structures and operational flowcharts, provides an explicit and inherent disclosure of the apparatus, method, and computer-readable medium claims of the ’599 patent.

Prior Art Relied Upon: Rosenberg (Patent 7,577,522).
Core Argument for this Ground:
- Prior Art Mapping: This ground was presented as an alternative to anticipation. Petitioner argued that to the extent Rosenberg is found not to explicitly disclose certain system components recited in the claims (e.g., a "context manager" or "content delivery mechanism" as distinct modules), a person of ordinary skill in the art (POSITA) would have found it obvious to implement Rosenberg’s system using such components.
- Motivation to Combine (for §103 grounds): A POSITA would have been motivated to structure the software and hardware of Rosenberg’s system using dedicated modules for functions like managing context and delivering content. This was a well-known and common design choice for organizing complex systems, improving modularity, and simplifying development and maintenance.
- Expectation of Success: A POSITA would have had a high expectation of success in implementing these modular components, as it represented a straightforward application of conventional software architecture principles to the system described in Rosenberg.

Prior Art Relied Upon: Rosenberg (Patent 7,577,522) and Suzuki (Patent 6,680,675).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Rosenberg teaches the foundational context-aware reminder system, while Suzuki teaches modifying such a system to make reminders "sharable" among multiple users. Certain dependent claims of the ’599 patent add limitations related to sharing content pieces and rules between users.
- Motivation to Combine (for §103 grounds): A POSITA would combine Rosenberg's system with Suzuki’s teachings on sharable reminders to improve the system's efficiency and versatility. Suzuki explicitly discusses the inefficiency of un-sharable to-do lists, which can lead to redundant task performance (e.g., two users on a shared shopping trip buying the same item). Adding a sharing capability would have been a recognized improvement to Rosenberg’s personal reminder system.
- Expectation of Success: Implementing a sharing function was a known technique at the time. A POSITA would have readily understood how to modify Rosenberg's database to associate reminders with multiple user IDs, as suggested by Suzuki, with a predictable and successful outcome.

Petitioner argued that discretionary denial under §314(a) based on the Fintiv factors would be inappropriate. The petition asserted that the parallel district court case was in its infancy with minimal investment by the parties. Furthermore, Petitioner stated its intent to file a motion to stay the litigation pending the outcome of the IPR, noting the presiding court consistently grants such motions. To mitigate concerns of overlap, Petitioner also stipulated that it would not pursue in the district court any invalidity ground on which IPR is instituted.

Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of Patent 8,489,599 as unpatentable on all asserted grounds.