Snap Inc v. UberFan LLC

1. Case Identification

• Case #: IPR2022-00750
• Patent #: 9,477,744
• Filed: April 6, 2022
• Petitioner(s): Snap Inc.
• Patent Owner(s): UberFan, LLC
• Challenged Claims: 1-20

2. Patent Overview

• Title: Media Management System
• Brief Description: The ’744 patent relates to a media management system that associates media content, such as videos from a sporting event, with contextual event-related data. The system analyzes media file metadata, matches it with stored event data (e.g., game information, discrete actions, event segments), tags the media with the matched data, and provides access to the tagged media files.

3. Grounds for Unpatentability

Ground 1: Obviousness over Grandin and SportsData - Claims 1-20 are obvious over Grandin in view of SportsData.

• Prior Art Relied Upon: Grandin (Patent 6,378,132) and SportsData (a 2012 publicly available website and data feed service).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Grandin disclosed the core functionality of the challenged claims: an event capture system that receives video signals, matches them with time-stamped annotations (describing plays and game segments), tags the video with these annotations, and provides tag-based access to the annotated video. However, Grandin’s description of the annotation data was general. SportsData, a publicly known data feed service at the time, allegedly supplied the specific, hierarchical event data recited in the claims, including detailed game data (ID, venue, teams), event segment data (quarters, possessions), and discrete action data (plays). The combination of Grandin’s system with SportsData’s detailed feeds allegedly rendered the claims obvious.
  • Motivation to Combine: A POSITA would combine SportsData's detailed, structured data feeds with Grandin's system to improve it. Grandin provided a functional framework for tagging video with event data, and a POSITA would have naturally sought out comprehensive, commercially available data sources like SportsData to populate that framework. This would predictably enhance the system's categorization, search, and retrieval capabilities by providing more specific and useful metadata tags.
  • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved substituting a known element (Grandin’s general annotation data) with a more specific, but functionally equivalent, known element (SportsData’s comprehensive data feeds). This was a basic data integration task for a known type of database system to achieve the predictable result of improved searchability.

Ground 2: Obviousness over Grandin, Olsen, and Salmi - Claims 1-20 are obvious over Grandin in view of Olsen and Salmi.

• Prior Art Relied Upon: Grandin (Patent 6,378,132), Olsen (Application # 2010/0043040), and Salmi (Application # 2015/0178968).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground presented an alternative combination for the same purpose as Ground 1. Grandin again provided the foundational system for matching and tagging video with annotations. Olsen was cited for its teaching of creating video clips from multiple camera feeds using a time-synchronized game annotation file containing information about teams, plays, and play boundary times. Salmi was cited for teaching a system that matches a user-captured image's time and location data to a corresponding event and tags the image with relevant information like the score and period. Together, Olsen and Salmi demonstrated the same type of detailed, time-based event data that SportsData provided in Ground 1.
  • Motivation to Combine: The motivation was the same as in Ground 1: to improve Grandin's system by incorporating more detailed and specific types of event, event segment, and discrete action data. A POSITA would have been motivated to utilize the data types taught by Olsen and Salmi to provide more robust options for annotation and tagging within Grandin’s framework, thereby enhancing the system's overall functionality.
  • Expectation of Success: A POSITA would have expected success in combining these references as they all related to identifying and segmenting sporting events using metadata tags to improve searchability. The integration of Olsen's and Salmi's more specific data into Grandin's database system was argued to be a straightforward application of conventional data management techniques.

• Additional Grounds: Petitioner asserted that claims 1-20 are obvious over Grandin, SportsData, and Wong (Patent 9,081,798), and that claims 11-12 are obvious over Grandin, Olsen, Salmi, and Wong. These grounds relied on Wong's teachings of using media content's time, location, and hashtags to identify and tag it with event-related data to provide further options for contextual matching.

4. Key Claim Construction Positions

• “Contextual Information”: Petitioner argued this term should be construed as “data relating to the context (e.g., setting, conditions, or circumstances) of a media content item.” This construction was based on its plain meaning and use in the specification to describe data like timestamps and GPS locations used to match media to an event.
• “Automatically Tag[ging]”: Petitioner proposed this term means “associating metadata with a digital file in a system without user intervention.” This construction was argued to be consistent with the specification's description of the system's automated processing steps after receiving media and event data.
• “Provid[e/ing] Access”: Petitioner argued this term means “making media content available for viewing, searching, or other interactions,” reflecting the various ways the patent described users interacting with the tagged media content.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate.
  • Denial under §325(d) was argued to be improper because the primary prior art references (Grandin, SportsData, Olsen, Salmi, Wong) were not considered by the examiner during the original prosecution of the ’744 patent.
  • Denial under Fintiv was argued to be unwarranted because the co-pending district court litigation was in its early stages, with a trial date more than a year and a half away and claim construction not yet underway. Petitioner asserted that an inter partes review (IPR) would resolve the validity of all asserted claims efficiently and that it would not assert in district court any grounds that were raised or could have reasonably been raised in the IPR.

6. Relief Requested

• Petitioner requested the institution of an IPR and the cancellation of claims 1-20 of Patent 9,477,744 as unpatentable under 35 U.S.C. §103.