PTAB

IPR2022-01142

Unified Patents LLC v. Ak Meeting IP LLC

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1. Case Identification

2. Patent Overview

  • Title: Multi-Client Communication and Shared Content Display
  • Brief Description: The ’124 patent relates to a method for computer-supported cooperative work where multiple client computers communicate via a server over a network. The method involves a client generating messages from user input, sending them to the server, and the server in turn transmitting output messages back to all clients—including the originating client—to display shared content over a common content area.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 8 are Anticipated or Obvious over Roy

  • Prior Art Relied Upon: Roy (Patent 5,838,909).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Roy, which describes methods for reducing network latency in multi-player online games, discloses every element of the challenged claims. Roy teaches a client-server architecture where client computers send user input "events" (the claimed "messages") to a central server to update a shared game world. The server then sends "rendering commands" (the claimed "output messages") to all clients, explicitly including the sending client, to update their displays with the shared content. Petitioner contended this round-trip communication, designed to ensure a consistent game state for all players, directly maps to the method of claim 1. For claim 8, Petitioner asserted that the inherent network delay associated with sending an event to the server and receiving a rendering command back inherently discloses the claimed latency limitation.
    • Motivation to Combine (for §103): To the extent Roy was not found to anticipate, Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to apply Roy's established client-server architecture for gaming to other forms of collaborative work to ensure data consistency, a common goal in the field.
    • Expectation of Success: A POSITA would have had a high expectation of success in applying Roy's teachings, as the underlying network communication protocols were well-known and their application predictable.

Ground 2: Claims 1-14 are Obvious over Simonoff in view of Naef

  • Prior Art Relied Upon: Simonoff (Patent 7,043,529), Naef (Patent 5,206,934).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Simonoff discloses a "White Board" collaborative system where clients send "user-generated objects" (e.g., drawings, text) as commands to a server for retransmission to other clients. While Simonoff describes multicasting commands to receiving clients, it does not explicitly teach sending the commands back to the originating client. Petitioner asserted that Naef supplies this missing element. Naef, which relates to computer conferencing, discloses sending user action commands "to at least one remote user and the local user itself" to prevent data conflicts. The combination of Simonoff's collaborative server system with Naef's teaching of returning input messages to the sender was alleged to render the claims obvious.
    • Motivation to Combine: A POSITA would combine the references for two primary reasons. First, Simonoff explicitly incorporates the disclosure of Naef by reference "for all purposes." Second, a POSITA would have recognized the benefit of applying Naef's technique to Simonoff's system. Returning messages to the source client is a known method to improve collaborative systems by ensuring the originating user sees their edits exactly as others do, thereby avoiding data conflicts.
    • Expectation of Success: A POSITA would have reasonably expected success in making the combination, as it involved implementing a known, predictable programming technique within Simonoff's conventional client-server architecture to achieve a well-understood benefit.

Ground 3: Claims are Anticipated or Obvious over Chang

  • Prior Art Relied Upon: Chang (Zheng (Eric) Chang, A Framework Design for Collaborative GIS Applications: Based on Hybrid Architecture (2005 Thesis)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Chang, a master's thesis on computer-supported cooperative work (CSCW) software, anticipates the challenged claims. Chang describes centralized and hybrid architectures for collaborative applications. In these systems, a client sends "event messages" generated from user interactions to a "collaboration server." Critically, Chang explicitly teaches that the server then distributes these messages to "every client who joins the same session including the client who creates the event." Petitioner argued this express disclosure of returning output messages to the originating client anticipates the core method of claims 1 and 8. Chang further discloses specific user inputs like drawing lines and typing text, which Petitioner mapped to the limitations of various dependent claims.
    • Motivation to Combine (for §103): For any claims not fully anticipated, Petitioner argued it would have been obvious for a POSITA to implement the general CSCW features discussed by Chang (e.g., text-based chat, application sharing) within its specific collaborative framework, as these were common and desirable features in groupware at the time.
    • Expectation of Success: Success would have been expected because Chang presents these architectures and features as known and established in the field, making their implementation a matter of routine design choice.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Roy alone and expanded its obviousness challenge over Chang to cover additional dependent claims, relying on the same core teachings and design modification theories.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of Patent 10,963,124 as unpatentable.