Snap Inc v. UberFan LLC

1. Case Identification

• Case #: IPR2022-00753
• Patent #: 10,963,439
• Filed: March 29, 2022
• Petitioner(s): Snap Inc.
• Patent Owner(s): Uberfan, LLC
• Challenged Claims: 1-22

2. Patent Overview

• Title: Media Management System
• Brief Description: The ’439 patent relates to a media management system for mobile devices. The system associates media content, such as photographs captured at an event, with contextual event-related data (e.g., sports game information) received from a server to "contextualize" the media.

3. Grounds for Unpatentability

Ground 1: Claims 1-18 and 21-22 are obvious over Salmi in view of Instagram.

• Prior Art Relied Upon: Salmi (an international patent application) and Instagram (an archived webpage from Instagram's Help Center).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Salmi taught the core functionality of the challenged claims. Salmi disclosed a smartphone application that captures a photograph at a sporting event, transmits contextual information (capture time and location) to a server, and receives corresponding event data (e.g., team names, score, period) to overlay on the photograph. However, Petitioner asserted Salmi only broadly mentioned applying filters using applications like Instagram. Instagram was argued to supply the missing details for a special effects user interface, disclosing a "tray" of selectable filters (a "special effects control") that can be tapped to modify the appearance of a photograph. The combination of Salmi's system and Instagram's UI for applying filters allegedly rendered the claims obvious.
  • Motivation to Combine: A POSITA would combine Salmi and Instagram because Salmi itself expressly taught using Instagram to apply filters to photographs before sharing. Petitioner argued this created a direct motivation to incorporate Instagram's known UI features into Salmi's system to implement the filtering functionality. The combination would have simply provided predictable implementation details for a feature already contemplated by the primary reference.
  • Expectation of Success: Petitioner contended a POSITA would have had a high expectation of success. The combination involved implementing a well-known iPhone application (Instagram) on the exact platform for which it was designed (an iPhone, which Salmi disclosed as an example device). This was described as a straightforward, "plug-and-play" integration of existing technologies.

Ground 2: Claims 19 and 20 are obvious over Salmi in view of Instagram and further in view of Jobs.

• Prior Art Relied Upon: Salmi, Instagram, and Jobs (Patent 7,479,949).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Salmi and Instagram and added the teachings of Jobs to address the limitations of claims 19 and 20, which required displaying media content in a "timeline display" that could be scrolled via a swipe input. Petitioner asserted Jobs taught the standard iPhone "Camera Roll" feature, which organized photo thumbnails in a time-ordered grid (a "timeline display"). Jobs further disclosed that a user could scroll through this grid using vertical swipe gestures to navigate to different views of the timeline.
  • Motivation to Combine: Petitioner argued a POSITA would combine Jobs with the Salmi/Instagram system to provide an intuitive and cohesive user interface for navigating captured photographs on the iPhone platform. Since Salmi explicitly disclosed using an iPhone, a POSITA would have been motivated to implement well-known, native iPhone features, such as the Camera Roll interface taught by Jobs, for photo management to enhance the user experience. This was not a substitution, but rather filling in implementation details with standard features of the disclosed device.
  • Expectation of Success: Success would have been highly probable because Jobs merely detailed the functionality of a standard, pre-existing feature of the iPhone. No modification to the systems of Salmi or Instagram was required; it was an application of a known UI technique to a known platform to perform a conventional function (viewing photos).

4. Key Claim Construction Positions

• "Contextual Information" (claims 1, 10, 16, 22): Petitioner proposed this term means "data relating to the context (e.g., setting, conditions, or circumstances) of a media content item." This construction was based on examples in the specification, such as time stamps and GPS locations, which provide context for when and where media was captured.
• "Special Effects Control" (claims 1, 7, 9, 10, 14, 16): Petitioner proposed this term means "a user-operated control to selectively apply or adjust a special effect." This was crucial to mapping Instagram's filter "tray" to the claims.
• "Timeline Display" (claims 19, 20): Petitioner proposed this term means "a display of media content in time or date order." This construction was key to mapping the iPhone's chronologically-ordered "Camera Roll" feature from Jobs to the claims.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under both §325(d) and the Fintiv factors.
• §325(d): Petitioner asserted that denial would be inappropriate because the grounds relied on prior art (Salmi, Instagram, and Jobs) that was neither presented to nor considered by the examiner during prosecution. The new art was argued to be materially different and not cumulative to the previously cited references, particularly in its teaching of a special effects control.
• Fintiv Factors: Petitioner argued that the parallel district court litigation was in its early stages, with the claim construction hearing and trial dates set far in the future. Given the early stage of litigation and the strength of the petition's merits, Petitioner contended that institution would promote efficiency and serve the integrity of the patent system.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-22 of the ’439 patent as unpatentable.