PTAB

IPR2023-00757

Netflix Inc v. GoTV Streaming LLC

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1. Case Identification

2. Patent Overview

  • Title: Generating Content Renderable by a Wireless Device
  • Brief Description: The ’715 patent describes methods and systems for generating content for wireless devices within a client-server architecture. The system uses a "custom configuration" to define the look and feel of an application on the device, and transmits "compiled content" from a server to be rendered by the device's graphical user interface 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 Hariki discloses the core framework of the challenged claims, while Harris supplies the missing details regarding device-specific content generation. Hariki describes a client-server system where a server transmits a "UI content package" to a mobile device to customize the "look and feel" of the application environment. Petitioner contended this package corresponds to the claimed "custom configuration" (the resource files) and its "identification" (the description file). The customizable elements in Hariki, such as backgrounds, buttons, and alert sounds, were argued to be the claimed "plurality of rendering blocks." Hariki’s system sends this configuration to a wireless device, meeting the "transmitting" limitation.

    Petitioner asserted that while Hariki discloses sending content like HTML files, it lacks detail on generating content tailored for specific devices. Harris was argued to fill this gap by teaching a platform that generates content in a generic markup language (WAX) and then translates it into a device-specific language (e.g., HTML) based on the device's capabilities. This device-specific HTML, containing basic commands (tags) for rendering, was mapped to the claimed "compiled content." Harris further contemplates serving multiple pages in response to user requests, which Petitioner mapped to the claimed "first compiled content specific to a first page" and "second compiled content specific to a second page." The generation of this content based on the execution of both the server and client browser applications was argued to meet the limitation that compiled content is "generated in part from execution of said application."

    • Motivation to Combine: A POSITA would combine Hariki with Harris to improve Hariki’s system for customizing and delivering content. Hariki provides a system for customizing a device’s UI but is not explicit about how the underlying application content (like web pages) is generated and tailored. Harris provides a detailed and compatible method for doing exactly that—generating device-specific content from a generic template. Petitioner argued a POSITA would have been motivated to integrate Harris’s sophisticated content generation and translation engine into Hariki’s customization framework to create a more efficient and capable system for delivering a fully customized user experience on a variety of mobile devices.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success. Both Hariki and Harris operate in the same technical field, describing client-server architectures for delivering content to mobile devices. The underlying technologies, such as generating HTML, customizing UIs, and client-server communication, were well-understood and commonplace. Combining Harris's content-generation techniques with Hariki's UI customization framework would have been a predictable integration of known elements to achieve an improved, but obvious, system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is not warranted. It asserted that the scheduled trial date in the parallel district court litigation (GoTV Streaming, LLC v. Netflix, Inc., C.D. Cal.) is likely to occur after the statutory deadline for a Final Written Decision (FWD) in the IPR. Petitioner also noted that the district court case is in its early stages, with no substantive orders issued or expert reports prepared. Furthermore, Petitioner stipulated that if the IPR is instituted, it will not pursue the same invalidity grounds in the district court.
  • Denial under 35 U.S.C. §325(d) was argued to be inappropriate because the petition raises new arguments based on prior art (Hariki and Harris) that was never considered by the examiner during the original prosecution of the ’715 patent. This is the first IPR petition filed against the challenged claims.

5. Relief Requested

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