Meta Platforms Inc v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2024-00249
• Patent #: 9,619,578
• Filed: December 6, 2023
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Mobile Data Technologies, Inc.
• Challenged Claims: 1-19, 21-22

2. Patent Overview

• Title: Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks
• Brief Description: The ’578 patent describes a system where users can manage content for a mobile website through a separate content management website. This system allows users to activate and manage "mobile information channels" (M-channels) to make various types of information, such as photos and messages, accessible on mobile devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-19 and 21-22 are obvious over Neibauer, Ausems, Cheng, and Squibbs

• Prior Art Relied Upon: Neibauer (a 2000 book, How to Do Everything With Yahoo!), Ausems (Patent 6,434,403), Cheng (Patent 7,574,486), and Squibbs (Application # 2001/0015759).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of references teaches every limitation of the challenged claims. Neibauer discloses the core functionality through its description of "Yahoo! Clubs," a service allowing users to create web-based communities to share photos, messages, and other content. This service provides a "first interface" for uploading photos and a "second interface" for club members to view the shared content in an album, which Petitioner asserted is an "application-based information channel." Cheng teaches a proxy server system that reformats existing web pages for optimal viewing on mobile devices, addressing the "via a mobile device" limitation. Ausems discloses a mobile device (a PDA/phone combination) with an integrated digital camera, satisfying the limitation that media data is "captured by the mobile device." Finally, Squibbs teaches a system for associating captured photos with GPS location data and displaying the geo-tagged photos on a map, which addresses limitations related to integrating location-based information.
  • Motivation to Combine: A POSITA would combine these references to meet the clear market demand for mobile access to popular web services. Neibauer itself suggested making Yahoo! services available on mobile devices. A POSITA would have been motivated to use Cheng’s well-known proxy server technology to adapt Neibauer's "Yahoo! Clubs" for mobile users, providing a simple, "bolt-on" solution. Adding Ausems's teaching of integrated cameras was a natural progression to allow users to share content they create "in the moment" rather than just pre-existing files. Incorporating Squibbs's location-tagging functionality would have been an obvious way to improve the user experience by making photo albums more organized and contextually rich, a known problem that Squibbs explicitly sought to solve.
  • Expectation of Success: Petitioner contended a POSITA would have had a high expectation of success because each element of the combination relied on well-understood, conventional technologies (web communities, proxy servers, mobile cameras, GPS) being used for their intended purposes.

Ground 2: Claims 1-19 and 21-22 are obvious over Neibauer, Ausems, Cheng, and Squibbs in further view of Harvey

• Prior Art Relied Upon: The prior art from Ground 1, plus Harvey (Patent 6,487,583).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative to Ground 1 to address a specific claim construction of "application-based information channel" proposed by Petitioner in co-pending litigation. This construction requires "a virtual location at the content management site at which user-authored content may be added." While Petitioner argued the primary combination met this, it introduced Harvey to conclusively teach this feature. Harvey discloses a system for creating online communities where the creator can use a configuration tool to author and add initial content (e.g., welcome messages, photos) before the community is launched and made available to other users.
  • Motivation to Combine: The motivation for adding Harvey to the primary combination was to provide club founders with greater customization and control over the initial user experience. By allowing a founder to pre-populate a club's information channels with content before other members join, as taught by Harvey, the founder could ensure that the club was not an empty "blank" space upon creation. This would create a more engaging and welcoming experience for new members from the moment of launch.
  • Expectation of Success: Success was reasonably expected as Harvey's community creation tools were analogous to Neibauer's club creation features, and integrating the ability to add content during setup was a straightforward software design choice.

4. Key Claim Construction Positions

• The petition noted an ongoing dispute in parallel litigation over the term "application-based information channel."
• Patent Owner's proposed construction, which Petitioner was willing to adopt for the purposes of the inter partes review (IPR), is "a computer program-based medium for transferring information." Petitioner argued its primary combination (Ground 1) satisfies this construction.
• Petitioner's own proposed construction is "a virtual location at the content management site at which user-authored content may be added for transmission to the mobile web site." Ground 2 was presented to ensure this more specific construction was also rendered obvious by the prior art.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) based on Fintiv factors would be inappropriate. It asserted that the co-pending district court litigation is in a very early stage, with no substantive discovery, claim construction, or expert reports having occurred, thus minimizing any concerns of duplicative efforts or inefficient use of resources.
• Petitioner also argued against denial under §325(d), which addresses previously presented art. While Neibauer, Cheng, and Squibbs were listed on an Information Disclosure Statement (IDS) during prosecution, Petitioner contended the Examiner never substantively reviewed or relied upon them in any rejection. Petitioner asserted the Examiner materially erred by failing to appreciate how these references, particularly in combination, rendered the claims obvious.

6. Relief Requested

• Petitioner requested institution of an IPR and cancellation of claims 1-19 and 21-22 of the ’578 patent as unpatentable.