Snap Inc v. UberFan LLC

1. Case Identification

• Case #: IPR2022-00751
• Patent #: 9,727,634
• Filed: April 14, 2022
• Petitioner(s): Snap Inc.
• Patent Owner(s): Uberfan, LLC
• Challenged Claims: 1-21

2. Patent Overview

• Title: Media Management System
• Brief Description: The ’634 patent relates to a media management system that automatically tags media content, such as videos from a sporting event, with contextual event-related data. The system matches media content with stored data based on time and other contextual information, then applies tags to the media to facilitate searching and access.

3. Grounds for Unpatentability

Ground 1: Claims 1-21 are obvious over Grandin in view of SportsData.

• Prior Art Relied Upon: Grandin (Patent 6,378,132) and SportsData (publicly available webpages from sportsdatallc.com, 2012).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Grandin taught the core claimed method: an event capture system that receives video signals and time-stamped annotations for a sports game, matches them based on timestamps, and generates new "distribution annotations" (tags) to allow for query-based access. Grandin's annotations included information about game segments and discrete plays. Petitioner asserted that SportsData, a well-known source of real-time sports data feeds, disclosed the specific hierarchical event data (e.g., game ID, quarter, drive, play-by-play) that the ’634 patent claims. While Grandin taught the system, SportsData taught the comprehensive data to use within it.
  • Motivation to Combine: A POSITA would combine Grandin's system with the detailed, hierarchical data from SportsData to improve the functionality and commercial appeal of Grandin’s system. Using more comprehensive and specific metadata tags from a known data source like SportsData was a simple and predictable way to enhance the categorization and searchability of the tagged videos.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining the references merely involved using a known type of data (SportsData's feeds) to populate a known type of database system (Grandin's annotation system). This was a basic data management task to achieve a predictable improvement in search relevance.

Ground 2: Claims 1-21 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 to SportsData for the source of detailed event data. Petitioner argued that Olsen taught creating video clips using a game annotation file containing information about teams, play boundary times, and specific play events (e.g., end of quarter, change of possession). Salmi taught a system where a server receives time and location data from a user's captured image, matches it to a corresponding event, and tags the image with event information (e.g., score, period, teams playing).
  • Motivation to Combine: A POSITA would have been motivated to incorporate the teachings of Olsen and Salmi into Grandin’s system to provide more robust annotation options and improved matching capabilities. For example, Salmi’s use of time and location data for matching would provide a richer way to identify relevant events for Grandin's video signals, while Olsen’s detailed annotation files provided another source of comprehensive event data to improve searchability.
  • Expectation of Success: The combination was a simple substitution of one known element (Grandin's annotation data) for other known elements (the more comprehensive data from Olsen and Salmi) to obtain the predictable result of improved tagging and searchability.

• Additional Grounds: Petitioner asserted additional obviousness challenges for various claims based on combinations including Wong (Patent 9,081,798), which taught tagging digital content with event data based on metadata like time, GPS, and hashtags, and Jin (Patent 9,047,375), which taught accessing online video content using URL links provided in response to keyword searches.

4. Key Claim Construction Positions

• "Contextual Information": Petitioner argued this term, not explicitly defined in the patent, should be construed as "data relating to the context (e.g., setting, conditions, or circumstances) of a media content item." This includes data associated with the media before and after matching, such as keywords, timestamps, and GPS locations.
• "Automatically Tag[ging]" / "Automatically Generat[e/ing] a Tag": Petitioner proposed that "automatically tagging" means "associating metadata with a digital file in a system without user intervention" and "automatically generating a tag" means "generating metadata for a digital file in a system without user intervention."

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §325(d), stating that the prior art references relied upon in the petition were not considered by the examiner during the original prosecution of the ’634 patent.
• Petitioner further argued that discretionary denial under Fintiv would be inappropriate because the parallel district court litigation was in its early stages. Key milestones like claim construction briefing and the trial itself were scheduled far in the future (March 2023 and December 2023, respectively), making a stay likely if the IPR was instituted. Petitioner contended that the strong merits of the petition and the potential to resolve the entire district court matter weighed heavily in favor of institution.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of Patent 9,727,634 as unpatentable.