PTAB

IPR2021-01259

Avery Dennison RFID Co v. Evrythng Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Mapping Tagged Objects to Context-Aware Applications
  • Brief Description: The ’321 patent discloses methods and systems for context-aware redirection. The system involves a user device scanning a tag on an object to obtain an object identifier and a server address, then sending a request with the identifier and contextual information (e.g., user ID, location, time) to a "context-aware redirector server" that uses a "rules database" to map the request to a specific application "entry point" and redirects the user device.

3. Grounds for Unpatentability

Ground 1: Anticipation over Lim - Claims 1-7, 9-11, and 13-29 are anticipated by Lim

  • Prior Art Relied Upon: Lim (Application # 2012/0223131).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lim discloses every element of the challenged claims. Lim describes a system where a user scans a QR code (a tag) on an object, which contains a unique "hardlink code" (an object identifier) and a server URL. The user's device sends a request containing the code and contextual variables (e.g., time of day, geographic location) to a server system. The server uses an internal database with pre-stored rules to select and deliver content, including redirecting the user to one of a plurality of "merchant site addresses" (entry points) for independent applications based on the combination of the unique code and the contextual variables.

Ground 2: Obviousness over Lim and Chor - Claims 1-29 are obvious over Lim in view of Chor

  • Prior Art Relied Upon: Lim (Application # 2012/0223131), Chor (Application # 2012/0036226), and a POSITA’s common knowledge.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Lim provides the foundational context-aware redirection system. Chor was argued to supplement Lim's teachings by disclosing a similar system that uses "short URLs" or "unique URIs" (as object identifiers) that redirect to different "destination URIs" (entry points) based on "conditional specifiers" (contextual information). Chor’s use of short URIs, which contain less data, is taught as a solution for mobile devices with low-fidelity scanners incapable of reading information-dense barcodes.
    • Motivation to Combine: A POSITA would combine Lim and Chor to improve the functionality of Lim's system. Specifically, a POSITA would have been motivated to implement Lim's QR codes using Chor's short, unique URIs to ensure the system was accessible to a wider variety of mobile devices, including those with less capable hardware, as explicitly suggested by Chor.
    • Expectation of Success: Both references describe solutions for the same problem in the same technical field. A POSITA would have found it straightforward to apply Chor's teachings on URI structure to Lim's system architecture with a high expectation of success.

Ground 3: Obviousness over Fitzpatrick and Herzig - Claims 1-7, 9-11, and 13-29 are obvious over Fitzpatrick in view of Herzig

  • Prior Art Relied Upon: Fitzpatrick (Application # 2008/0201305), Herzig (Application # 2011/0000958), and a POSITA’s common knowledge.

  • Core Argument for this Ground:

    • Prior Art Mapping: Fitzpatrick discloses a "code triggered information server" (CTIS) that delivers context-specific content (e.g., ads, links to articles/videos) based on scanned codes and a wide array of contextual data (user ID, location, time, hardware ID). Herzig was cited for its efficient method of URL redirection using a simple look-up table stored in memory, which maps a scanned short URL to a longer redirection URL.
    • Motivation to Combine: A POSITA would combine the references to implement Fitzpatrick's complex, rule-based content delivery system with Herzig’s efficient and well-understood look-up table database structure. This modification would allow advertisers in Fitzpatrick's system to directly edit the redirection associations in a simple mapping table, which aligns with Fitzpatrick’s stated design goal of allowing advertisers to "finely tune and efficiently tailor their efforts."
    • Expectation of Success: Using look-up tables was a well-known and conventional database implementation technique. A POSITA would have readily applied Herzig’s specific look-up table redirection method to Fitzpatrick’s system as a predictable and successful design choice.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the primary combinations in further view of Rabetge (Application # 2009/0125612) to teach the use of a "RUN" as an entry point for claim 8, and Makower (Application # 2002/0184507) to teach the use of a third-party identity provider for claim 12.

4. Key Claim Construction Positions

  • "Entry Point": Petitioner proposed this term be construed as "a predefined address or identification stored in the rules database prior to receiving a redirection request." This construction was argued to be supported by the claims and specification, emphasizing that the redirection targets are pre-stored and associated with specific rules.
  • "Rules Database": Petitioner proposed this term be construed as a "database that stores object identifiers, contextual information, and entry points, and has associations that each link a specific combination of object identifier and contextual information to a specific entry point." This construction highlights the key-value pair structure where a combination of identifier and context (the key) maps to a specific entry point (the value).

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The core reasons provided were that this was the first and only IPR filed against the ’321 patent, the petition presented strong grounds for unpatentability, and the parallel district court litigation was in its earliest stages, with the Patent Owner not yet having answered the complaint and patent invalidity not having been raised.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-29 of Patent 9,794,321 as unpatentable.