Meta Platforms Inc v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2024-00246
• Patent #: 8,793,336
• Filed: December 6, 2023
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Mobile Data Technologies, Inc.
• Challenged Claims: 1, 6-11, 13-18, 20-21, 23-27

2. Patent Overview

• Title: Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks
• Brief Description: The ’336 patent describes a system where a user can access a content management website to activate and manage "mobile information channels" (M-channels). These channels, such as chat or photo sharing, are then made available on a corresponding mobile website, facilitating interaction and content sharing between the primary user and additional users over wireless networks.

3. Grounds for Unpatentability

Ground 1: Obviousness over Neibauer, Miller, and Cheng - Claims 1, 6-11, 13-18, 20-21, 23-27 are obvious over Neibauer in view of Miller and Cheng.

• Prior Art Relied Upon: Neibauer (a 2000 book, How to Do Everything With Yahoo!), Miller (WO 00/17775), and Cheng (Patent 7,574,486).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of these references teaches all limitations of the challenged independent claims. Neibauer disclosed "Yahoo! Clubs," a service allowing a first user to create a web-based community with features like message boards, chat rooms, and photo sharing. These features correspond to the claimed "mobile information channel." The user interface for creating a club in Neibauer was mapped to the "first web-based interface," while the resulting club pages were mapped to the "second web-based interface." To address the limitation that a user can selectively activate specific channels, Petitioner cited Miller, which taught a system for creating collaborative web environments where a user could select from a list which communication features (e.g., bulletin board) to include. To render the channels "mobile" and accessible "over a wireless network," Petitioner relied on Cheng, which taught a proxy server system for automatically converting any standard HTML website for optimal viewing on mobile devices.
  • Motivation to Combine: A POSITA would combine Neibauer with Miller to enhance the flexibility and customizability of Yahoo! Clubs, allowing creators to tailor the features to their group's specific needs. The motivation to add Cheng was driven by the strong and growing market demand for mobile access to web services. Cheng provided a well-known, "bolt-on" technological solution to make existing web content, like Neibauer's Yahoo! Clubs, available to mobile users without needing to re-engineer the underlying service, thereby simplifying implementation.
  • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying conventional web programming and well-known proxy server transcoding techniques to existing, compatible web services.

Ground 2: Obviousness over Ground 1 Art in view of Ausems - Claim 7 is obvious over the combination of Neibauer, Miller, and Cheng in view of Ausems.

• Prior Art Relied Upon: The prior art from Ground 1, plus Ausems (Patent 6,434,403).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground specifically addressed the limitations of dependent claim 7, which required shared content to be obtained from a "device-captured data source," such as "device-captured image data." While Petitioner contended the primary combination already rendered this obvious, Ausems was added as it explicitly disclosed a portable mobile device (a PDA with a wireless telephone) that included an integrated digital camera for capturing and transmitting images.
  • Motivation to Combine: A POSITA would have been motivated to incorporate the teachings of Ausems to expand the universe of content that users could share within their online communities. Allowing users to capture images with their mobile devices and directly upload them to their club was a natural and predictable extension of the functionality taught in Neibauer.

Ground 3: Obviousness over Ground 1 Art in view of Fransioli - Claims 21-22 are obvious over the combination of Neibauer, Miller, and Cheng in view of Fransioli.

• Prior Art Relied Upon: The prior art from Ground 1, plus Fransioli (Application # 2004/0198396).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground targeted claims 21 and 22, which required "personalized messaging content" and the integration of "location-based service information." Fransioli disclosed a system for delivering personalized messages (e.g., advertisements, traffic reports) to a user's mobile device based on its current location and direction of travel.
  • Motivation to Combine: A POSITA would have been motivated to combine Fransioli's teachings to enhance the user experience by providing more relevant, location-based content. Fransioli itself stated its system "provides localized and personalized information content in ways that improve over existing systems," providing an express reason to integrate its location-aware features into a communication platform like that disclosed by Neibauer.

• Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 4-6) that were substantially similar to Grounds 1-3 but added Harvey (Patent 6,487,583). Harvey was included solely to address a potential claim construction of "mobile information channel" advanced by Petitioner in co-pending litigation.

4. Key Claim Construction Positions

• Petitioner argued that while no express claim construction was necessary for the IPR, it addressed disputed terms from parallel litigation. The key disputed term was "mobile information channel."
• Patent Owner's Position (in litigation): The term should be construed as "a medium for transferring information that allows mobile device users to author content." Petitioner asserted its primary grounds satisfy this construction.
• Petitioner's Position (in litigation): The term should be construed as "a virtual location at the content management site at which user-authored content may be added for transmission to the mobile web site." Petitioner presented alternative grounds (Grounds 4-6 with Harvey) to prove obviousness under this construction as well.

5. Arguments Regarding Discretionary Denial

• §314(a) / Fintiv: Petitioner argued against discretionary denial, stating that the co-pending district court litigation was in its early stages with no substantive discovery completed. Petitioner further offered a stipulation that, if the IPR is instituted, it will not pursue in litigation any invalidity defense that was raised or reasonably could have been raised in the IPR.
• §325(d) / Advanced Bionics: Petitioner argued against denial, acknowledging that Neibauer and Cheng were listed on an Information Disclosure Statement during prosecution. However, Petitioner contended the Examiner never substantively reviewed them, as no prior art rejections were ever made; the prosecution focused solely on a double-patenting rejection. Petitioner asserted the Examiner materially erred by failing to appreciate that these references disclosed the very limitations the Examiner found missing from other art.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1, 6-11, 13-18, 20-21, and 23-27 of the ’336 patent as unpatentable under 35 U.S.C. §103.