PTAB

IPR2023-00757

Netflix Inc v. GoTV Streaming LLC

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1. Case Identification

2. Patent Overview

  • Title: Method of Generating Content Renderable by a Wireless Device
  • Brief Description: The ’715 patent relates to a client-server system for delivering customized applications to wireless devices. The technology separates application data into a "custom configuration," which defines the user interface's "look and feel," and "compiled content," which contains the application's page-specific data rendered using that configuration.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Hariki in view of Harris.

  • Prior Art Relied Upon: Hariki (Application # 2007/0150617) and Harris (Application # 2003/0023755).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Hariki and Harris renders all challenged claims obvious under 35 U.S.C. §103. Hariki was asserted to teach the foundational client-server architecture for customizing mobile device interfaces. Specifically, Hariki discloses a server that generates and transmits a "UI content package" or "UI skin" to a mobile device to alter the "look and feel" of the display and sound. Petitioner contended this UI package corresponds to the claimed "custom configuration" and that its configurable elements (e.g., backgrounds, buttons, alert sounds) meet the definition of "rendering blocks." Hariki also describes its server sending web pages (e.g., HTML files) to the mobile device, which corresponds to the claimed "compiled content."

      Petitioner asserted that Harris remedies a perceived deficiency in Hariki by providing a detailed method for generating device-specific content. While Hariki describes sending web pages, Harris explicitly teaches a platform for generating tailored markup language (like HTML or WML) from a generic, device-independent template (WAX) by consulting a device capability registry. Petitioner argued that this process in Harris directly maps to the claimed limitations of generating and transmitting "compiled content" specific to the wireless device, including first and second pages of an application. The combination of Hariki's framework for separating a customizable UI skin from application content, with Harris's detailed method for generating that application content in a device-specific manner, allegedly teaches every limitation of the independent claims. For example, dependent claims reciting audio/display content, remote server execution, and content specific to rendering capabilities were argued to be taught by Hariki's disclosure of UI skins with sound files and Harris's teaching of tailoring content via a device registry.

    • Motivation to Combine: Petitioner argued that a Person of Ordinary Skill in the Art (POSA) would combine Hariki and Harris to create a more robust and efficient system. A POSA reviewing Hariki's system for delivering customizable UIs would recognize that it lacks specific detail on how to generate the associated content pages (e.g., HTML files) for a variety of different mobile devices. To address this, the POSA would have been motivated to look to a reference like Harris, which operates in the same technical field and provides a known solution for generating device-specific content from a generic template, thereby improving Hariki’s functionality.

    • Expectation of Success: Petitioner asserted a POSA would have had a reasonable expectation of success in this combination. Both references describe compatible client-server architectures, and the techniques for generating and rendering HTML on mobile devices were well-understood. Integrating Harris's content generation scheme into Hariki's customization framework would have been a straightforward application of known technologies to achieve the predictable result of a more capable and versatile content delivery platform.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors is unwarranted. The key arguments asserted were that: (1) the median time-to-trial in the parallel C.D. Cal. litigation (22.9 months) makes it unlikely to conclude before a Final Written Decision (FWD); (2) the district court has not made significant substantive investments in the case; and (3) Petitioner stipulated not to pursue the same invalidity grounds in the district court if an IPR is instituted.
  • Petitioner further contended that denial under §325(d) would be inappropriate. The petition is the first IPR challenge filed against the ’715 patent, and the primary prior art references, Hariki and Harris, were not cited or considered during the original prosecution, meaning the Patent Office has not previously addressed these arguments.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-20 of the ’715 patent as unpatentable.