Meta Platforms Inc v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2024-00247
• Patent #: 8,825,801
• Filed: December 6, 2023
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Mobile Data Technologies, Inc.
• Challenged Claims: 1-25

2. Patent Overview

• Title: Method, Apparatus And System For Management Of Information Content For Enhanced Accessibility Over Wireless Communication Networks
• Brief Description: The ’801 patent discloses a system where a user can utilize a content management website to activate and manage "mobile information channels" (M-channels) for a mobile website. These M-channels are intended to facilitate the generation and management of content, allowing users to share information via collaborative workspaces, data mailboxes, or other mobile site types accessible via wireless devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-25 are obvious over Neibauer, Miller, Cheng, and Squibbs.

• Prior Art Relied Upon: Neibauer (a 2000 book, How to Do Everything With Yahoo!), Miller (International Publication No. WO 00/17775), Cheng (Patent 7,574,486), and Squibbs (Application # 2001/0015759).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the prior art combination taught every limitation of the challenged claims. Neibauer’s disclosure of "Yahoo! Clubs" taught the core functionality of independent claim 1, including an interface for a first user (a club founder) to create a community (the "mobile information channel") with features like message boards, chat, and photo sharing for multiple users. Miller taught an interface allowing a group creator to selectively choose which communication features to include, fulfilling the "control activation" limitation. Cheng taught a proxy server system that could convert any existing website for optimal viewing on a mobile device, thereby rendering Neibauer's web-based clubs "mobile." Finally, Squibbs taught a system for capturing photos with associated GPS location data and displaying them on a map, which Petitioner mapped to the limitations of dependent claims 2, 3, 6, and 14 requiring location-based information.
  • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would have been motivated to combine these references for predictable results. A POSITA would have combined Neibauer and Miller to provide enhanced flexibility and customizability for online communities, a known design goal. There was a strong motivation to combine this system with Cheng to meet market demand for making popular web services accessible on the growing number of mobile devices; Cheng’s "create-once, deliver anywhere" approach offered a clear technical advantage. A POSITA would have integrated Squibbs’s teachings to improve the user experience of Neibauer’s photo-sharing feature, solving the known problem of photo classification by adding valuable location context.
  • Expectation of Success: Success was expected because the combination involved the straightforward application of known technologies: adding customizable features to a web platform (Miller), using a proxy server for mobile web conversion (Cheng), and integrating GPS data with digital photos (Squibbs).

Ground 2: Claims 1-25 are obvious over Neibauer, Miller, Cheng, and Squibbs in further view of Harvey.

• Prior Art Relied Upon: All prior art from Ground 1, plus Harvey (Patent 6,487,583).
• Core Argument for this Ground: This ground was presented primarily to address a specific claim construction of "mobile information channel" proposed by Petitioner in co-pending litigation.
  • Prior Art Mapping: Petitioner argued that Harvey disclosed techniques for creating online communities where the creator could use a configuration editor to author and add content (e.g., initial messages or application objects) to the community before it was launched and made available to other users. This preemptive content creation directly addressed the key feature of Petitioner's proposed construction.
  • Motivation to Combine: A POSITA would have been motivated to combine Harvey's pre-launch content authoring with the system of Ground 1 to provide a better user experience. This would allow a club founder to populate the club's message board or photo albums with initial content, ensuring new members did not encounter a "blank" or empty community. This would create a more engaging club from the moment of its creation, which was a clear and desirable design goal.
  • Expectation of Success: Petitioner contended the combination required only the application of conventional web development techniques to achieve a predictable result.

4. Key Claim Construction Positions

• The petition addressed the disputed claim term "mobile information channel," which was central to the invalidity arguments.
• Petitioner argued that the prior art rendered the claims obvious under any reasonable construction, including two competing constructions from the co-pending litigation.
• For the purposes of the IPR, Petitioner stated it would adopt the Patent Owner's proposed construction: "a medium for transferring information that allows mobile device users to author content." Petitioner argued that Neibauer's message boards and chat features plainly met this definition.
• As an alternative, Petitioner presented Ground 2 to expressly address its own, narrower proposed construction: "a virtual location at the content management site at which user-authored content may be added for transmission to the mobile web site." The addition of Harvey was intended to satisfy the temporal aspect of adding content at the management site for later transmission.

5. Arguments Regarding Discretionary Denial

• Petitioner presented arguments against discretionary denial under both 35 U.S.C. §314(a) and §325(d).
• Fintiv Factors (§314(a)): Petitioner argued that discretionary denial under Fintiv was unwarranted because the co-pending litigation was in its early stages, with no substantive discovery conducted and a trial date far in the future. To further allay concerns of duplicative efforts, Petitioner provided a stipulation that, if the inter partes review (IPR) is instituted, it will not pursue in litigation any invalidity defense that was or could have been raised in the petition.
• Advanced Bionics Framework (§325(d)): Petitioner contended that denial would be improper because the Examiner did not substantively consider the key prior art. The petition argued that three of the primary references—Miller, Squibbs, and Harvey—were never presented to the USPTO. While Neibauer and Cheng were listed on an Information Disclosure Statement, they were never applied in a rejection or analyzed by the Examiner. Petitioner asserted this constituted a material error, as these references taught the very limitations the Examiner found missing from the closest prior art of record during prosecution.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of Patent 8,825,801 as unpatentable.