Meta Platforms Inc v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2024-00251
• Patent #: 10,839,427
• Filed: December 6, 2023
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Mobile Data Technologies, Inc.
• Challenged Claims: 1-9

2. Patent Overview

• Title: Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks
• Brief Description: The ’427 patent describes a system where a user can utilize a "content management website" to create and manage "mobile information channels" (M-channels) for a mobile website. This allows users to select information from various sources and have it automatically formatted and generated as mobile-accessible resources.

3. Grounds for Unpatentability

Ground 1: Obviousness over Neibauer and Cheng - Claims 1-3 and 5-9 are obvious over Neibauer in view of Cheng.

• Prior Art Relied Upon: Neibauer (a 2000 book entitled "How to Do Everything With Yahoo!") and Cheng (Patent 7,574,486).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Neibauer, which describes the Yahoo! Clubs service, discloses the "content management resources" of independent claim 1. Specifically, Neibauer taught that a user could create a club (a web-based community) and manage its content, including designating and adding a photo from an external source (the user's local computer) to the club's homepage. This maps to providing content management resources at a URL that permit a user to designate data from an external source. The limitations of uploading, reformatting, and automatically generating mobile resources were argued to be obvious in view of Cheng. Cheng disclosed a proxy server that could intercept a request for a standard webpage, retrieve it from its origin server, and then automatically reformat the page and its content (including images) for optimal viewing on a mobile device.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Neibauer with Cheng to make the popular Yahoo! Clubs service accessible to the growing market of mobile device users. Neibauer itself disclosed other Yahoo! services for mobile devices, making the extension of its Clubs feature a logical next step. Cheng provided a known, "bolt-on" solution to adapt any existing website for mobile use without altering the original site, offering a clear technological and market-driven incentive for the combination.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because Cheng’s proxy server transcoding relied on well-known, industry-standard technologies for converting web content into formats suitable for mobile devices.

Ground 2: Obviousness over Neibauer, Cheng, and Balabine - Claim 4 is obvious over the combination for Ground 1 in view of Balabine.

• Prior Art Relied Upon: Neibauer (a 2000 book), Cheng (’486 patent), and Balabine (Patent 5,937,406).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon Ground 1 to specifically address dependent claim 4, which requires that the external data source comprises a "database source." While Neibauer disclosed selecting a file from a local computer, Balabine taught a system for making objects within a database accessible to applications as if they were standard files in a file system. Petitioner contended that adding Balabine’s teaching would render it obvious that the user's photo in Neibauer could be sourced from a local database rather than a simple file system.
  • Motivation to Combine: A POSITA would be motivated to incorporate Balabine’s teachings to gain the known advantages of using databases over file systems, such as more structured data organization and faster, more complex querying capabilities. Balabine’s system was designed to be transparent to the application (e.g., the web browser in Neibauer), providing an easy way to enhance the underlying data source without modifying the user-facing functionality.

Ground 3: Obviousness over Neibauer, Cheng, and Yates - Claims 1 and 4-9 are obvious over the combination for Ground 1 in further view of Yates.

• Prior Art Relied Upon: Neibauer (a 2000 book), Cheng (’486 patent), and Yates (Patent 6,167,438).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative to Ground 1 to address a potential claim construction requiring the "second set of one or more servers" (where data is uploaded) and the "third set of one or more servers" (from which reformatted data is included) to be different. In this combination, the proxy server from Cheng represented the "second set." Yates, which taught a network of distributed caching servers, provided the "third set." After the Cheng proxy server reformatted a webpage, the data could be stored on a separate Yates-style cache server closer to the end-user, from which it would be delivered to the mobile device.
  • Motivation to Combine: A POSITA would be motivated to add the distributed caching taught by Yates to the Neibauer/Cheng system to improve network performance. Yates expressly explained that caching reduces bandwidth consumption, decreases data retrieval times, and balances network load—all significant and predictable benefits for delivering popular web content, such as the club pages from Neibauer, to a large number of users.

4. Key Claim Construction Positions

• Petitioner argued that while no express construction was necessary, the claims would be obvious even under the constructions proposed by the parties in co-pending litigation.
• The key disputed term was "content management resources." Petitioner noted that Patent Owner proposed a plain-meaning construction (e.g., "content" means "data," "management" means "administration"). Petitioner argued the prior art satisfied this. Petitioner also noted its own proposed litigation construction ("a web site that allows a user without programming to create and manage content on a mobile web site") was also met by the proposed combination of Neibauer and Cheng.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv): Petitioner argued against discretionary denial under Fintiv, stating that the co-pending district court litigation was in a very early stage with no substantive discovery, claim construction, or trial date set. Petitioner also represented that, if the IPR is instituted, it will not pursue in litigation any invalidity defense that was or could have been raised in the IPR.
• §325(d): Petitioner argued that denial was not warranted because the primary references (Neibauer and Cheng) were not substantively considered during prosecution. Although they were listed on an Information Disclosure Statement (IDS), the Examiner never applied them in a rejection, instead allowing the claims over different art. Petitioner asserted that the Examiner materially erred by failing to appreciate the significance of these references.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-9 of the ’427 patent as unpatentable.