Apple Inc v. DoDots Licensing Solutions LLC

1. Case Identification

• Case #: IPR2024-00143
• Patent #: 8,020,083
• Filed: November 13, 2023
• Petitioner(s): Apple Inc.
• Patent Owner(s): DoDots Licensing Solutions LLC
• Challenged Claims: 1-16

2. Patent Overview

• Title: Accessing and Viewing Internet Content
• Brief Description: The ’083 patent describes a system for accessing and viewing internet content using software components called "application media packages" or "networked information monitors." These packages contain definitions for a graphical user interface and a URL pointing to internet content to be displayed within that interface on a client device.

3. Grounds for Unpatentability

Ground 1: Claims 1-5 and 9-13 are obvious over Brown (Ground 1A); Claims 1-16 are obvious over Brown in view of Wecker (Ground 1B).

• Prior Art Relied Upon: Brown (Patent 6,278,448) and Wecker (Patent 6,449,638).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Brown discloses all features of the challenged claims. Brown teaches a method of creating a "composite desktop" from web content using distinct "desktop components" implemented as floating frames. Petitioner asserted these "desktop components" are the claimed "networked information monitors" and that the "HTML instructions" defining them are the claimed "networked information monitor templates." For Ground 1B, Petitioner argued that to the extent Brown does not explicitly teach storing a plurality of templates, Wecker supplies this limitation. Wecker describes a system that uses "script templates" and stores them in a "cache memory," which Petitioner equated to the claimed "electronic storage."
  • Motivation to Combine (for §103 grounds): Petitioner asserted a POSITA would combine Brown and Wecker because both references address accessing internet content, use Microsoft's Channel Definition Format (CDF), and were assigned to Microsoft, suggesting compatibility. Brown explicitly directs a POSITA toward additional references discussing CDF, which would lead one to Wecker. Combining Wecker's efficient caching of script templates with Brown's composite desktop components was argued to be a predictable way to improve performance and usability, particularly for storing and retrieving multiple content modules.
  • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success due to the shared technological underpinnings (Windows operating system, HTML, CDF) and the common goal of displaying web content. The combination was presented as an application of known techniques to yield predictable results.

Ground 2: Claims 1-16 are obvious over Shimada in view of Buchholz.

• Prior Art Relied Upon: Shimada (Patent 6,789,263) and Buchholz (Patent 6,088,340).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of Shimada and Buchholz teaches all limitations. Buchholz discloses a wireless communication system where a portable unit receives a "pack" comprising a "bundle of templates" for formatting data. Petitioner mapped Buchholz's "bundle of templates" stored in memory to the claimed "plurality of networked information monitor templates" stored in "electronic storage." Shimada discloses a system for converting and displaying "screen configuration data" (written in HTML) that defines screens with content, frames, and controls (buttons, anchor tags). Petitioner argued Shimada's configurable screens and their underlying HTML data correspond to the claimed "networked information monitors" and "templates," respectively.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Shimada and Buchholz because both are directed at solving the problem of long download times in networks with limited transmission capacity. Both systems use HTML-based data structures to define the user interface. Petitioner argued that incorporating Shimada's method for efficiently defining screen configurations into Buchholz's template-based system for portable devices would be a logical step to enhance performance and reduce latency, a key objective in both references.
  • Expectation of Success (for §103 grounds): A POSITA would expect success because both systems rely on HTML, making their respective data structures (Shimada's "screen configuration data" and Buchholz's "templates") compatible. The combination was framed as the application of a known technique (Shimada's data formatting) to a similar system (Buchholz's portable device framework) to achieve a predictable improvement in data transfer efficiency.

4. Key Claim Construction Positions

• "networked information monitor" ("NIM"): Petitioner adopted the Patent Owner's prior construction, arguing the term should mean "a fully configurable frame, with one or more controls, through which content is presented to the user." This construction was central to mapping Brown's "desktop components" and Shimada's "screens" to the claims.
• "networked information monitor template": Petitioner argued this term should be construed as "a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that excludes executable applications/compiled code." This construction was critical for asserting that the HTML-based instructions in the prior art, which are markup languages and not compiled code, met the claim limitation.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under the General Plastic, Fintiv, and Advanced Bionics factors. The petition was filed as a "Joinder Petition" with a conditional motion to join an already-instituted IPR filed by Samsung (IPR2023-00621), promoting judicial efficiency. Petitioner contended that parallel district court litigation is not active, as the case was transferred from the Western District of Texas to the Northern District of California and no new proceedings had commenced, thus the Fintiv factors favor institution. Furthermore, Petitioner argued that the primary prior art references (Wecker, Shimada, Buchholz) were never applied during prosecution, and Brown was only listed on an IDS without substantive examination, weighing against denial under §325(d).

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-16 of Patent 8,020,083 as unpatentable.