Snap Inc v. UberFan LLC

1. Case Identification

• Case #: IPR2022-00752
• Patent #: 10,740,305
• Filed: April 11, 2022
• Petitioner(s): Snap Inc.
• Patent Owner(s): Uberfan, LLC
• Challenged Claims: 1-18

2. Patent Overview

• Title: Generating Intelligent Media Content
• Brief Description: The ’305 patent describes a media management system that receives media content (e.g., videos) and associates it with contextual, event-related data. The system matches media to data, tags the media with the matched data, and provides access to the tagged media content.

3. Grounds for Unpatentability

Ground 1: Claims 1-18 are obvious over Grandin in view of SportsData

• Prior Art Relied Upon: Grandin (Patent 6,378,132) and SportsData (a collection of webpages from sportsdatallc.com captured by the Internet Archive in 2012).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Grandin taught the core functionality of the ’305 patent, including an event capture system that receives video signals and time-stamped annotations (e.g., plays, game segments) and matches them based on time to create tagged, searchable video clips. However, Grandin’s annotations were relatively simple. SportsData, a publicly available printed publication, disclosed detailed, real-time sports data feeds with a hierarchical structure (game, quarter, play) organized by timestamp. Petitioner asserted that combining SportsData’s comprehensive event-related data with Grandin’s system would render obvious the claimed method of storing event data, receiving media, identifying contextual information (like timestamps), and automatically tagging the media with event, segment, and discrete action data.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to improve Grandin’s system by using the more specific and comprehensive event data available from sources like SportsData. This combination would enhance the categorization, searchability, and overall utility of the generated video clips, which was a recognized goal in the art.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved substituting one known type of data (Grandin’s annotations) with a more detailed but functionally similar type of data (SportsData’s feeds) within a conventional database and matching framework. Adding more detailed data fields to a database system was a routine and predictable task.

Ground 2: Claims 1-18 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 supplying the detailed event data to be combined with Grandin’s base system. Petitioner contended that Olsen taught creating video clips from multiple cameras using a game annotation file containing information about teams, players, and play boundary times. Salmi taught a system where a user-captured image’s time and location information is sent to a server, which matches it to a corresponding event and tags the image with relevant data like score, period, and teams playing. The combination of Grandin with the annotation and real-time tagging methods of Olsen and Salmi allegedly rendered the challenged claims obvious.
  • Motivation to Combine: The motivation was similar to Ground 1: to improve the media content categorization, access, and review capabilities of Grandin’s system. A POSITA would have looked to references like Olsen and Salmi to incorporate more comprehensive and automated data tagging to make Grandin’s system more powerful and efficient.
  • Expectation of Success: Success would have been expected because Olsen and Salmi teach applying tags to improve media categorization using the same basic methodology of matching media to event data based on time and other contextual information, making their integration with Grandin’s system straightforward.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Grandin, SportsData, and Wong (Patent 9,081,798) to teach using hashtags and other contextual data for matching (Ground 3), and combining Grandin, Olsen, Salmi, and Wong for claims 8-9 (Ground 4).

4. Key Claim Construction Positions

• “Contextual Information”: Petitioner argued this term has no special meaning in the art and 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 use in the patent specification to describe data like keywords, timestamps, and locations used to identify whether media relates to a specific event.
• “Automatically Tag[ging]”: Petitioner proposed this term means “associating metadata with a digital file in a system without user intervention.” This construction was derived from the patent’s description of “tagging” as associating metadata for searchability and “automatically” as occurring without direct user input for the tagging step itself.
• “Provid[e/ing] Access”: Petitioner contended this term means “making media content available for viewing, searching, or other interactions.” This interpretation was based on the patent’s abstract and specification, which describe providing access to media for viewing and searching.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under both 35 U.S.C. §325(d) and §314(a) (Fintiv factors).
• §325(d): Denial would be inappropriate because the petition relied on grounds and prior art (Grandin, SportsData, Olsen, Salmi, Wong) that were not presented to or considered by the examiner during the original prosecution.
• Fintiv Factors: Petitioner argued the factors strongly favored institution. The parallel district court case was in its very early stages, with claim construction briefing and hearings not scheduled for many months and a trial date more than a year and a half away. Petitioner asserted that the IPR would resolve the validity of all asserted claims, promoting efficiency and simplifying the district court case. Petitioner also committed not to pursue in district court any grounds raised or that reasonably could have been raised in the IPR if instituted.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-18 of the ’305 patent as unpatentable.