PTAB

IPR2023-00342

Intuit Inc v. Samesurf Inc

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1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for the Implementation of a Real-Time, Sharable Browsing Experience on a Guest Device
  • Brief Description: The ’591 patent discloses a system for collaborative web browsing (“co-browsing”), enabling multiple users to share a synchronized internet browsing session. The system architecture involves a host device, a guest device, and a synchronization server that facilitates the real-time sharing of webpage interaction data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lebrun and Wang - Claims 1-18 are obvious over Lebrun in view of Wang.

  • Prior Art Relied Upon: Lebrun (International Publication No. WO 00/48110) and Wang (Application # 2005/0033656).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lebrun discloses the core elements of the challenged claims, including a method and apparatus for synchronized "group-surfing." Lebrun’s system uses a "group-surfing server" (analogous to the ’591 patent’s synchronization server) to manage a session between multiple "web clients" (analogous to host and guest devices). Lebrun teaches creating a session, joining a session via a message containing an "identifier," and the server sharing webpage data, including URLs and cookie information, among participants to maintain synchronization. Petitioner asserted that Wang, which teaches a collaborative online shopping system, remedies Lebrun’s lack of an explicit clickable hyperlink for joining a session. Wang discloses sending an invitation containing a "dedicated URL address" that an invited user can click to join the session. The combination of Lebrun's group-surfing system with Wang's hyperlink invitation mechanism was argued to render independent claims 1 and 10 obvious. Petitioner further mapped elements of Lebrun and Wang to the limitations of dependent claims 2-9 and 11-18, such as receiving an invitation via email and distinguishing between shared and non-shared browsing interactions.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Lebrun and Wang because both references address the same problem: enabling multiple users to browse web pages collaboratively. A POSITA would have recognized that incorporating Wang’s well-known and user-friendly hyperlink invitation into Lebrun’s system was a predictable solution to streamline the process of joining a group session. This combination would simply apply a known technique (hyperlink invitations) to a similar system (Lebrun’s group-surfing) to yield predictable results.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination, as it involved applying conventional web programming techniques to integrate a standard hyperlink feature into a collaborative browsing framework.

Ground 2: Obviousness over Prajapat and Wang - Claims 1-18 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 argued that Prajapat discloses a "peer-to-peer dynamic web page sharing" system that teaches a method for "co-browsing." Prajapat's system uses "web media servers" as synchronizing agents, analogous to the ’591 patent’s synchronization server. The system allows a first browser to initiate a co-browsing session with a second browser by communicating information such as a URL. Prajapat discloses that the web media servers synchronize the retrieval and display of web content, including session information and cookies, on participating browsers. As in Ground 1, Petitioner relied on Wang to supply the teaching of using a clickable hyperlink to join the session. Petitioner argued that combining Prajapat’s co-browsing architecture with Wang's use of a "dedicated URL address" in an invitation would render the method of claim 1 and apparatus of claim 10 obvious. The remaining dependent claims were argued to be obvious over the combination for reasons similar to those in Ground 1, including teachings related to invitation methods (e.g., email) and handling of browsing interaction data.
    • Motivation to Combine: Petitioner asserted that a POSITA would combine Prajapat and Wang to improve the efficiency and user experience of Prajapat’s system. Prajapat teaches initiating a session by identifying a user via an email address, while Wang provides a more direct method using a clickable URL. A POSITA would have been motivated to incorporate Wang’s hyperlink invitation into Prajapat’s co-browsing system to provide a more convenient and effective way for users to join a shared session. Both references are in the same field of collaborative web browsing, making the combination a common-sense design choice.
    • Expectation of Success: A POSITA would have reasonably expected success in integrating Wang’s hyperlink functionality into Prajapat’s system, as it would involve using standard, well-understood web technologies to achieve a predictable outcome.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’591 patent as unpatentable under 35 U.S.C. §103.