PTAB

IPR2021-01413

Unified Patents LLC v. MemoryWeb LLC

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1. Case Identification

2. Patent Overview

  • Title: Managing Digital Files
  • Brief Description: The ’228 patent describes a method for managing digital files by organizing and displaying them based on associated location data in a "map view" and based on people identified within the files in a "people view."

3. Grounds for Unpatentability

Ground 1: Claims 1-7 are obvious over Okamura in view of Flora

  • Prior Art Relied Upon: Okamura (Application # 2011/0122153) and Flora (Patent 6,714,215).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Okamura teaches the core method of the ’228 patent, including a system for managing digital content that displays files organized by location (a "cluster map display area") and by person (a "face cluster image display area"). A user can switch between these views by selecting tabs, analogous to the claimed "map view" and "people view." However, Petitioner asserted Okamura's map interface is less advanced than what is claimed. Flora was introduced to supply the limitations of an "interactive map" with multiple "selectable thumbnail images" at different locations. Flora discloses a scalable geographic map where icons representing media items are displayed at their corresponding locations. Selecting an icon opens a media viewer showing the files for that location. The combination of Okamura’s dual-view (location/people) system with Flora’s interactive map interface allegedly meets the limitations of independent claim 1.
    • Motivation to Combine: A POSITA would combine Okamura and Flora to improve the user experience. Implementing Flora’s interactive and scalable map would enhance Okamura's method for displaying location-based content, providing a user with improved awareness of where content was captured and a more intuitive interface for navigation. This would be a simple substitution of a known, superior map interface (Flora) for a basic one (Okamura) to achieve a predictable improvement.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references are in the same field of organizing digital content by location. The combination would have been predictable, involving the routine software modification of integrating Flora's map display functionality into Okamura's content playback application.

Ground 2: Claims 1-7 are obvious over Okamura, Flora, and Wagner

  • Prior Art Relied Upon: Okamura (Application # 2011/0122153), Flora (Patent 6,714,215), and Wagner (Application # 2011/0163971).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Okamura/Flora combination by adding Wagner. Petitioner argued that if the primary combination is found not to teach a single, updatable "interface" for displaying both the map and people views, Wagner supplies this teaching. Wagner describes user interfaces for electronic devices, including an updatable application window that can display different sets of objects and content based on user input. Wagner also provides an alternative teaching for displaying a location name (e.g., "San Francisco") associated with content in a location viewer.
    • Motivation to Combine: A POSITA would be motivated to implement the Okamura-Flora system within the updatable interface taught by Wagner to create a more efficient method for displaying and navigating content. Wagner's teachings would improve performance and conserve power on a computing device, a common goal in software design. The combination would simply involve displaying the location and people views from the primary combination within Wagner's more efficient interface framework.
    • Expectation of Success: Success would be predictable as all references relate to user interface design for content navigation. Integrating the combined Okamura-Flora system into Wagner's interface would involve known programming techniques with a predictable outcome.

Ground 3: Claims 1-7 are obvious over Okamura, Flora, and Gilley

  • Prior Art Relied Upon: Okamura (Application # 2011/0122153), Flora (Patent 6,714,215), and Gilley (Application # 2010/0172551).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Gilley to the primary Okamura/Flora combination to further support the "people view" limitations. Petitioner contended that if Okamura's disclosure of displaying a name with a person's thumbnail is found to be insufficient, Gilley provides an explicit teaching. Gilley describes organizing photos into albums based on the people in them and clearly shows a user interface displaying a person's name (e.g., "James") directly adjacent to their corresponding thumbnail image.
    • Motivation to Combine: A POSITA would incorporate Gilley's teachings to improve the usability and intuitiveness of the Okamura-Flora system's people view. Displaying names adjacent to faces, as taught by Gilley, provides an organizational scheme that helps users quickly understand the system's functioning and improves the accessibility of the photo library. This modification would be a straightforward enhancement to make the people view more user-friendly.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because combining the teachings would be a predictable improvement. The Okamura-Flora system already displays information related to people thumbnails, and modifying it to explicitly display names adjacently as taught by Gilley would be a routine software adjustment.

  • Additional Grounds: Petitioner asserted a fourth obviousness ground challenging claims 1-7 over the combination of all four references (Okamura, Flora, Wagner, and Gilley), relying on the same motivations and arguments presented in the grounds above.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise discretionary denial under Fintiv. It asserted that Fintiv is inapplicable because Petitioner is not a party to the parallel district court litigations involving the ’228 patent. Furthermore, Petitioner contended that the co-pending litigation was at an early stage and that the specific prior art and invalidity arguments raised in the petition had not been presented in that forum.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of the ’228 patent as unpatentable under 35 U.S.C. §103.