PTAB

IPR2023-00341

Intuit Inc v. Samesurf Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for the Implementation of a Real-Time, Sharable Browsing Experience on a Host Device
  • Brief Description: The 9,483,448 patent describes a system and method for enabling multiple users to share a synchronized internet browsing session across different devices and locations. The system is initiated by a host device that communicates with a synchronization server to establish the session and invite guest devices to join.

3. Grounds for Unpatentability

Ground 1: Claims 1-16 are obvious over Lebrun in view of Wang.

  • Prior Art Relied Upon: Lebrun (WO 00/48110) and Wang (Application # 2005/0033656).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lebrun discloses the fundamental elements of the challenged claims, including a "group-surfing system" for simultaneous web browsing among multiple users. In Lebrun, a "first web client" (the host device) initiates a "group-surfing session" by sending a "session-creation message" to a "group-surfing server" (the synchronization server). The server then informs participants and manages the session using an "identifier." Lebrun also teaches the concept of determining which web interactions are sharable via "look ahead" or "special access" modes. Petitioner contended that while Lebrun teaches sending invitations with an identifier, Wang supplies the common and obvious feature of using a clickable hyperlink ("dedicated URL address") for the invitation to make joining the session more user-friendly.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA), tasked with creating a convenient collaborative browsing system, would have been motivated to combine the references. Both Lebrun and Wang address the same problem of synchronized browsing. A POSITA would combine Lebrun's foundational group surfing system with Wang’s well-known use of a hyperlink for invitations as a predictable and simple improvement to enhance the user experience of joining a session.
    • Expectation of Success: The combination involved applying a known technique (hyperlink invitations) to a known type of system (collaborative browsing), which would predictably result in a more efficient session initiation process.

Ground 2: Claims 1-16 are obvious over Prajapat in view of Wang.

  • Prior Art Relied Upon: Prajapat (Application # 2005/0021626) and Wang (Application # 2005/0033656).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Prajapat discloses a "peer-to-peer dynamic web page sharing" system that allows users to "co-browse" webpages. This system uses "web media servers" for synchronization, which corresponds to the claimed synchronization server. In Prajapat, a user on a first browser can initiate a co-browsing session and invite another user, specifying their identity (e.g., by email address). Prajapat further teaches that users can request webpage content directly from a "web content server," independent of the synchronizing "web media server." Petitioner again relied on Wang to supply the obvious implementation of sending the session invitation with a clickable hyperlink to streamline the process for the invited user.
    • Motivation to Combine: A POSITA would combine Prajapat's co-browsing architecture with Wang's user-friendly invitation mechanism to improve the system's overall efficiency. Since both references operate in the same field of collaborative browsing, incorporating a hyperlink-based invitation from Wang into Prajapat's system was argued to be an obvious design choice to simplify the user workflow for joining a shared session.
    • Expectation of Success: Integrating a standard hyperlink invitation mechanism into Prajapat's co-browsing system was a straightforward application of known web technologies that would have yielded predictable improvements in usability, giving a POSITA a high expectation of success.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-16 of Patent 9,483,448 as unpatentable under 35 U.S.C. §103.