Twitch Interactive Inc v. RazDog Holdings LLC

1. Case Identification

• Case #: IPR2025-00307
• Patent #: 9,729,658
• Filed: December 23, 2024
• Petitioner(s): Twitch Interactive, Inc.
• Patent Owner(s): Razdog Holdings LLC
• Challenged Claims: 1-18

2. Patent Overview

• Title: Cloud-Based Computer System and Method
• Brief Description: The ’658 patent discloses a cloud-based system that aggregates content data and applications from multiple, user-selected sources. The system presents this content on a master web-page, allowing a user to scroll through the aggregated feeds using a "slide tool" and provides a "remote tool box" for customization, while collecting user analytics to target information.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Darnell and Kim - Claims 1-5 and 7-11 are obvious over Darnell in view of Kim.

• Prior Art Relied Upon: Darnell (Application # 2008/0086484) and Kim (Application # 2007/0016609).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Darnell taught the core cloud-based system of the independent claims. Darnell disclosed a server system that aggregates content feeds (e.g., RSS) from multiple host sources, stores them, and serves them to a client device through a unified, web-based user interface. This interface allowed users to pre-select subscribed feeds and included a scrollbar (a "slide tool") for navigation. To meet the "analytics" and "remote tool box" limitations, Petitioner relied on Kim. Kim taught an aggregated content feed system that organized content based on identified "traits" and tracked a user's "usage history" to determine which feeds were most popular, which Petitioner equated to collecting analytics. Kim also taught classifying content types like news, blogs, and email. The combination allegedly taught all limitations of the independent claims.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the references to solve the common problem of aggregating multiple content feeds for a user. A POSITA would have been motivated to implement Kim’s more sophisticated trait-based organization and usage-history analytics into Darnell’s server-based architecture to create a more robust and personalized user experience that was accessible from any device, not just the one where content was aggregated.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because both Darnell and Kim employed similar, compatible feed technologies (like RSS) and the combination represented a straightforward application of known content aggregation methods to yield predictable results.

Ground 1B: Obviousness over Darnell, Kim, and Dasgupta - Claims 6 and 12-18 are obvious over Darnell and Kim in view of Dasgupta.

• Prior Art Relied Upon: Darnell (’484 application), Kim (’609 application), and Dasgupta (Patent 8,640,052).
• Core Argument for this Ground: This ground builds on the Darnell and Kim combination by adding Dasgupta to teach the "purchase tool" limitation of claim 6 and related method limitations in the dependent claims.
  • Prior Art Mapping: Petitioner asserted Dasgupta taught a graphical user interface for media content that included a "virtual store." This feature presented users with selectable options to acquire (e.g., purchase, rent, or subscribe to) media content like videos and games directly from the interface, thereby teaching a purchase tool.
  • Motivation to Combine: A POSITA would have been motivated to incorporate Dasgupta’s virtual store into the Darnell/Kim system to enhance its functionality and provide a monetization path. Adding e-commerce capabilities to a content aggregation platform was a known business strategy to improve the system's usefulness while streamlining operations for the user.
  • Expectation of Success: Success was expected because providing purchase opportunities within a feed reader interface was well-known in the art, and Dasgupta demonstrated that such a feature was well within the skill of a POSITA.

Ground 2A: Obviousness over Dasgupta and Darnell - Claims 1, 4-10 are obvious over Dasgupta in view of Darnell.

• Prior Art Relied Upon: Dasgupta (Patent 8,640,052) and Darnell (’484 application).

• Core Argument for this Ground: This ground asserted that Dasgupta taught the primary cloud-based system for presenting aggregated media content but lacked specific features for user content selection and security, which were supplied by Darnell.

  • Prior Art Mapping: Petitioner argued Dasgupta disclosed a media content access system with a server (delivery subsystem) that streams content from multiple providers to a user device (access subsystem) over a network. The system presented this content in a graphical channel guide with selectable icons and personalized advertisements based on user profile data. However, Darnell was needed to explicitly teach user-created subscription lists and robust security features, such as a login mechanism using a user ID and token to authenticate requests and limit access.
  • Motivation to Combine: A POSITA would combine Darnell’s feed-subscription and security methods with Dasgupta’s media-content system to make user accounts more secure and provide better content personalization. Incorporating Darnell’s features would enhance Dasgupta’s user profile privacy and allow users to explicitly configure their desired content sources, which Dasgupta’s system was designed to accommodate.
  • Expectation of Success: A POSITA would have expected success because Dasgupta’s system was flexible ("any technologies suitable for accessing media content"), and adding a user login and subscription list from Darnell was a straightforward application of known techniques for enhancing control and security in content aggregation systems.

• Additional Grounds: Petitioner asserted additional obviousness challenges against claims 2, 3, and 11 based on the combination of Dasgupta, Darnell, and Kim, primarily adding Kim's teachings of specific content types like email and blogs to the primary Dasgupta/Darnell system.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv is inappropriate. The district court trial is scheduled for June 1, 2026, which is after the expected Final Written Decision (FWD) deadline in this inter partes review (IPR). Furthermore, the parallel litigation is in its early stages, with minimal investment by the court or parties. Petitioner also argued against denial under 35 U.S.C. §325(d), stating that the petition’s grounds rely on three prior art references, none of which were before the USPTO during the original prosecution of the ’658 patent.

5. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-18 of the ’658 patent as unpatentable.