Netflix Inc v. GoTV Streaming LLC

1. Case Identification

• Case #: IPR2023-00757
• Patent #: 8,478,245
• Filed: April 7, 2023
• Petitioner(s): Netflix, Inc.
• Patent Owner(s): GoTV Streaming, LLC
• Challenged Claims: 1-33

2. Patent Overview

• Title: Method and System for Rendering Content on a Wireless Device
• Brief Description: The ’245 patent discloses a client-server system for rendering content on wireless devices. The system separates the user interface’s “look and feel” from the content itself by having a server transmit an application-specific “custom configuration” and device-generic “compiled content” to a device, which then uses its native “rendering blocks” to generate and display the content as customized by the configuration file.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hariki and Harris - Claims 1-33 are obvious over Hariki in view of Harris under 35 U.S.C. §103.

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

  • Prior Art Mapping: Petitioner asserted that Hariki discloses the core architecture and functionality of the challenged claims. Hariki teaches a client-server system where a mobile device downloads a "UI content package" (the claimed "custom configuration") to customize its "look and feel." This package contains resource files that configure various UI elements like backgrounds, buttons, and alert sounds (the claimed "plurality of rendering blocks") for a specific application, such as a web browser. Hariki’s system allows the device’s appearance to be customized without modifying the underlying application.

    Petitioner contended that Harris supplies the teachings for generating and delivering the content to be rendered within Hariki’s framework. Harris discloses a system for authoring content in a generic, device-independent markup language (WAX) and then translating it into a device-specific format (the claimed "compiled content," such as HTML) based on the target device's capabilities. Harris explicitly teaches generating and delivering multiple, distinct pages of this tailored content to a mobile device, which corresponds to the ’245 patent’s limitation of receiving first and second compiled content for different application pages.

  • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Hariki’s UI customization system with Harris’s content generation and delivery method to create a more robust and efficient system. Hariki provides a method for customizing the UI "skin," while Harris provides a complementary method for generating and delivering the actual content (e.g., tailored HTML pages) to be displayed within that skin. A POSITA would be motivated to integrate Harris’s teachings to improve Hariki’s system by enabling the delivery of content that is specifically optimized for the device, a known goal in the art. The combination addresses the well-understood need to provide a rich, customized user experience on resource-constrained mobile devices.

  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. Both Hariki and Harris describe standard client-server architectures for serving content to mobile devices and were designed to solve related problems. Integrating Harris’s method for generating tailored HTML pages into Hariki's system, which already contemplates a mobile device receiving web pages, would have been a straightforward application of known web technologies. The result—a mobile device with a customizable UI rendering tailored content pages—would have been predictable.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors is not warranted. Petitioner asserted that the trial date in the parallel district court litigation is scheduled close to the statutory deadline for a Final Written Decision (FWD) and is likely to be delayed past the FWD date. Further, the court has not invested significant resources in the case, and Petitioner stipulated that it would not pursue the same invalidity grounds in district court if the IPR is instituted, promoting efficiency.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-33 of the ’245 patent as unpatentable.