Meta Platforms Inc v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2023-00250
• Patent #: 9,922,348
• Filed: December 6, 2023
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Mobile Data Technologies, Inc.
• Challenged Claims: 1-20

2. Patent Overview

• Title: Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks
• Brief Description: The ’348 patent discloses a system for managing information for mobile websites. The system uses a "content management website" that allows a user to activate and manage "mobile information channels" (M-channels), which facilitate the creation of mobile sites and the sharing of user-authored content within collaborative online communities.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Web and Mobile References - Claims 1-3, 6-9, 12-14, and 17-18 are obvious over Neibauer in view of Ausems and Cheng.

• Prior Art Relied Upon: Neibauer (a 2000 book on Yahoo! services), Ausems (6,434,403), and Cheng (7,574,486).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Neibauer's "Yahoo! Clubs" feature discloses a web-based community where users can share photos and messages, satisfying the core limitations of a "web-based shared information channel." Cheng was cited for its teaching of a proxy server that converts existing web pages into a format suitable for mobile devices, rendering Neibauer's features accessible on such devices. Ausems was asserted to disclose a mobile device (a PDA/phone combination) incorporating a digital camera, which meets the limitation of receiving "device-captured data" from mobile devices. Together, these references were alleged to teach all elements of the independent claims.
  • Motivation to Combine: A POSITA would combine Neibauer with Cheng to meet market demand for making popular desktop web features available on the growing number of mobile devices. Adding the teachings of Ausems was presented as a logical step to enhance user engagement by allowing users to capture and share original content directly from their devices, rather than being limited to pre-existing images.
  • Expectation of Success: Petitioner asserted a high expectation of success because the combination involves applying known technologies, such as Cheng’s proxy server and Ausems’s camera-equipped mobile device, to an existing web platform (Neibauer) for their intended purposes.

Ground 2: Obviousness with Location Data - Claims 4-5 are obvious over Neibauer, Ausems, and Cheng, in further view of Squibbs.

• Prior Art Relied Upon: The combination from Ground 1, plus Squibbs (2001/0015759).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on the core combination of Ground 1 to address dependent claims 4-5, which require location information. Petitioner argued Squibbs teaches a photo album system where digital photos are stamped with geographic location data (e.g., from a GPS receiver) and can be displayed on a map. This was asserted to directly teach the claimed "device-captured location coordinates" and "capture location-identifying information."
  • Motivation to Combine: A POSITA would combine Squibbs with the Ground 1 system to improve the user experience of the photo-sharing feature. Associating photos with location data provides valuable context, improves the classification of uploaded photos, and allows for new features like map-based browsing, which would be a natural extension of map features already present in Neibauer’s Yahoo! services.

Ground 3: Obviousness with Data Feeds - Claims 10-11, 15-16, and 19-20 are obvious over Neibauer, Ausems, and Cheng, in further view of McElfresh.

• Prior Art Relied Upon: The combination from Ground 1, plus McElfresh (6,907,566).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addresses dependent claims related to obtaining and integrating data from a "data feed," specifically advertisements. Petitioner argued that McElfresh discloses a system for integrating advertisements into a webpage by requesting them from an ad server. This ad server functions as the claimed "data feed," and McElfresh teaches integrating the received ads into the primary webpage content.
  • Motivation to Combine: The motivation to add McElfresh's teachings to the Ground 1 system was presented as being primarily commercial. A POSITA would be motivated to integrate a known ad-serving technique to generate revenue from the web-based community, a standard business practice for online services. McElfresh’s methods would improve upon Neibauer by allowing for more dynamic ad placement.

• Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 4-6) based on the same combinations as Grounds 1-3 but adding Harvey (6,487,583). Harvey was included to address Petitioner’s alternative proposed construction in parallel litigation for the term "web-based shared information channel."

4. Key Claim Construction Positions

• Petitioner argued that while no express constructions are necessary, the term "web-based shared information channel" is disputed in pending litigation. For the purposes of this IPR, Petitioner stated it is willing to adopt the Patent Owner's proposed construction: "a medium for transferring information accessible to more than one user via the internet." Petitioner contended the asserted prior art renders the claims obvious even under this construction.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv Factors): Petitioner argued against discretionary denial under Fintiv, stating that the co-pending district court litigation is at a very early stage with no significant discovery or claim construction events having occurred. To mitigate concerns of inefficiency, Petitioner stipulated that, if review is instituted, it would not pursue any invalidity ground in the litigation that it raised or reasonably could have raised in the IPR.
• §325(d) (Advanced Bionics): Petitioner contended that denial under §325(d) would be improper. It was argued that key references (Ausems, McElfresh, Harvey) were never before the examiner. For the references that were cited in an Information Disclosure Statement during prosecution (Neibauer, Cheng, Squibbs), Petitioner asserted they were never substantively considered or applied against the claims, as the only rejection made was on non-art, double-patenting grounds.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’348 patent as unpatentable.