Twitch Interactive Inc v. RazDog Holdings LLC

1. Case Identification

• Case #: IPR2025-00308
• Patent #: 10,334,068
• Filed: December 23, 2024
• Petitioner(s): Twitch Interactive, Inc.
• Patent Owner(s): Razdog Holdings LLC
• Challenged Claims: 1

2. Patent Overview

• Title: Cloud-Based Computer System
• Brief Description: The ’068 patent discloses a cloud-based computing system intended to solve the problem of requiring multiple logins to access content from different sources. The system uses a master server to aggregate content from various providers into a single, web-based user interface that features a "slide tool" for navigation and collects user analytics.

3. Grounds for Unpatentability

Ground 1: Obviousness over Darnell and Kim - Claim 1 is 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 that Darnell taught a cloud-based "content feed aggregation system" that meets most limitations of claim 1. Darnell’s system used a server to retrieve content feeds (e.g., RSS) from multiple host sources, aggregate them, and present them in a unified, web-based user interface on a remote client device. This interface included a scrollbar for navigating content. Petitioner contended Kim, which was cited during the prosecution of Darnell, taught the missing element of collecting analytics based on user interaction. Kim disclosed an aggregated content feed system that organized content based on identified "traits" and tracked a user's "usage history" to determine which content feeds were most often visited.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Darnell and Kim to solve the common problem of efficiently presenting aggregated content. Darnell provided the server architecture for aggregation, while Kim provided a known method for improving the relevance of that aggregated content by analyzing user interaction and history. A POSITA would have been motivated to apply Kim's technique of analyzing content traits and usage history to enhance the "score" system Darnell used for ordering content, thereby making the presented feeds more relevant and tailored to individual user preferences.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success, as combining known methods of content aggregation (Darnell) with known methods of user-based content filtering and organization (Kim) was a straightforward application of conventional techniques to achieve the predictable result of an improved user experience.

Ground 2: Obviousness over Dasgupta and Darnell - Claim 1 is obvious over Dasgupta in view of Darnell.

• Prior Art Relied Upon: Dasgupta (Patent 8,640,052) and Darnell (Application # 2008/0086484).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Dasgupta disclosed a cloud-based "media content access system" that streamed content from multiple provider subsystems to a user's device for display in a graphical user interface (GUI), such as an interactive channel guide. Dasgupta's GUI allowed a user to scroll through content channels and advertisements. Petitioner argued that this system constituted a cloud-based system with a master server, a master application for organizing content from multiple sources, and a slide tool. To the extent Dasgupta did not explicitly disclose certain features like pre-selecting content sources, Petitioner contended that Darnell supplied these teachings. Darnell explicitly taught a system where users "create a list of feed subscriptions," thereby pre-selecting content.
  • Motivation to Combine: A POSITA would combine the references as they both addressed aggregating large amounts of content into a single user interface. A POSITA would incorporate Darnell's explicit feed subscription and user-selection methods into Dasgupta’s media system to better organize and configure the media content sources. This combination would provide users with more control over the displayed content and enhance security by preventing unauthorized access, a known goal in the art.
  • Expectation of Success: A POSITA would have reasonably expected success in this combination. Incorporating Darnell's established feed selection and subscription techniques into Dasgupta's media access system represented a straightforward application of known, conventional content aggregation methods to achieve the predictable result of a more personalized and secure system.

4. Key Claim Construction Positions

• Petitioner stated it was unaware of any prior claim construction determinations but applied several meanings ascribed by the ’068 patent’s own specification to key terms.
• "master server": Construed as a dedicated server supporting a master program for accessing content from multiple sources through a single user interface.
• "master web-page": Construed as a remotely viewable web-page that displays a slide tool for scrolling through content from multiple sources in real time.
• Petitioner argued these constructions, derived from the patent itself, were consistent with the understanding of a POSITA and supported its obviousness arguments.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv is not warranted. 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 was in its early stages, with no claim construction orders issued or significant investment by the court.
• Petitioner also contended that denial under §325(d) would be inappropriate because the grounds in the petition relied on three prior art references (Darnell, Kim, and Dasgupta), none of which were before the Examiner during the original prosecution of the ’068 patent.

6. Relief Requested

• Petitioner requested the institution of an IPR trial and the cancellation of claim 1 of the ’068 patent as unpatentable.