Bright Data Ltd v. Oxylabs UAB

1. Case Identification

• Case #: IPR2023-01442
• Patent #: 7,020,667
• Filed: October 4, 2023
• Petitioner(s): Bright Data Ltd.
• Patent Owner(s): Metacluster LT, UAB
• Challenged Claims: 1-20

2. Patent Overview

• Title: System and Method for Data Retrieval and Collection in a Structured Format
• Brief Description: The ’667 patent describes a computer-implemented method for automatically extracting data from a source file on a public network, such as a web page, and collecting it in a target database. The system uses a two-stage process: an initialization stage where a user selects the source file, parses and identifies specific data elements to capture, and sets a scheduled frequency for retrieval, followed by an automatic execution stage that periodically transfers new data from the saved source locations to the target database.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are anticipated by DaCosta under 35 U.S.C. §102.

• Prior Art Relied Upon: DaCosta (Patent 6,826,553)
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that DaCosta discloses every limitation of the challenged claims. DaCosta describes a system for automatically extracting data from internet sources using scripts and storing it in a database repository. Petitioner asserted that DaCosta’s user-driven process of defining a navigation path and highlighting data for extraction corresponds to the claimed “initializing a data retrieval stage.” DaCosta’s parsing of HTML into a hierarchical list of elements, from which a user makes a selection, was alleged to meet the limitations of parsing data and selecting elements. The saving of “Navex scripts,” which contain source URL and navigation information, in a centralized repository was mapped to the claimed steps of identifying and saving source and target locations in a location file within the target database. Finally, Petitioner contended that DaCosta’s disclosure of automatically repeating extraction steps “in a scheduled manner” or using a server that “loops after a preset delay” to retrieve updated information directly teaches the claimed scheduling and automatic parsing/transferring of new data. For dependent claims, Petitioner argued DaCosta’s disclosure of using XML tags, servers, relational databases, and scripts for dynamic web pages met the respective limitations.

Ground 2: Claims 1-11 and 13-20 are anticipated by Kraft under 35 U.S.C. §102.

• Prior Art Relied Upon: Kraft (Application # 2003/0018669)
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Kraft discloses a system for saving web page content along with its associated context metadata, which anticipates the claims. Kraft's process, where a user inputs search parameters and navigates via hyperlinks to a target document to save it, was asserted to meet the "initializing a data retrieval stage" limitations. Petitioner contended that Kraft’s disclosure of parsing HTML tags and using hyperlinks as selectable data elements meets the parsing and selecting limitations. The system’s bundling of the target document with “context data,” including the source URL and navigation path, and storing it in a “destination documents repository” was alleged to teach saving source and target locations in a location file in a target database. Petitioner argued Kraft’s disclosure of running a crawler “periodically to update previously stored data” and using a “synchronization application” to update saved documents meets the scheduling and automatic data transfer limitations. The automatic comparison and updating of the destination document to reflect changes in the target document was alleged to teach the automatic parsing and transferring of new data elements.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) and the Fintiv factors is inappropriate. Petitioner asserted that factors 1, 3, and 4 weigh against denial because no stay has been sought in the parallel district court litigation, no substantive proceedings have occurred there, and the IPR challenges all 20 patent claims while the litigation involves only 7. Petitioner stipulated that, if instituted, it will not pursue the same invalidity grounds in the district court. While acknowledging that the scheduled trial date (December 2024) precedes the expected Final Written Decision (March 2025) and that the parties are the same (factors weighing for denial), Petitioner contended that the petition presents compelling evidence of unpatentability that serves the public interest and outweighs other factors.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’667 patent as unpatentable.