Samsung Electronics Co Ltd v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2025-00535
• Patent #: 9,032,039
• Filed: January 31, 2025
• Petitioner(s): Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc.
• Patent Owner(s): Mobile Data Technologies LLC
• Challenged Claims: 1-4, 8-9, 13-15, 17-25, 28-30

2. Patent Overview

• Title: Information Content Management for Network-Based Communication Systems
• Brief Description: The ’039 patent relates to network-based systems for managing information content. It discloses techniques where users can utilize "M-channels" on mobile devices to author and share content within collaborative workspaces, data mailboxes, or other types of mobile sites.

3. Grounds for Unpatentability

Ground 1: Obviousness over Neibauer, Cheng, Squibbs, and Ausems - Claims 1-4, 8-9, 13-15, 17-20, 22-25, 28-30 are obvious over the combination of four references.

• Prior Art Relied Upon: Neibauer (a 2000 book, "How to Do Everything With Yahoo!"), Cheng (Patent 7,574,486), Squibbs (Application # 2001/0015759), and Ausems (Patent 6,434,403).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the primary reference, Neibauer, discloses all aspects of a collaborative online community through its "Yahoo! Clubs" feature, which allowed users to create clubs, share photos, and post messages. To make this feature mobile-accessible, Petitioner asserted it would have been obvious to apply the teachings of Cheng, which describes a proxy server for converting standard web pages for viewing on mobile devices. To meet the "capturing content at a mobile device" limitation, Petitioner added Ausems, which teaches a mobile device (PDA telephone) with an integrated digital camera. Finally, to teach determining location information associated with the mobile device, Petitioner incorporated Squibbs, which discloses associating GPS location data with captured photos and displaying them on a map.
  • Motivation to Combine: A POSITA would combine Neibauer with Cheng to satisfy market demand for making popular web-based communities accessible on increasingly prevalent mobile devices. Combining Ausems was motivated by the desire to expand the universe of shareable content, allowing users to capture and upload images directly from their devices rather than being limited to pre-existing files. The motivation to add Squibbs stems from improving the user experience by providing a clear method for classifying and contextualizing photos based on geographic location, a known challenge that Neibauer's own Yahoo! Maps feature suggests was a pertinent area of interest.
  • Expectation of Success: A POSITA would have had a high expectation of success, as the combination relies on well-known and industry-standard technologies, including proxy servers for web adaptation (Cheng), integrated digital cameras in mobile devices (Ausems), and GPS for location tagging (Squibbs).

Ground 2: Obviousness over Neibauer, Cheng, Squibbs, Ausems, and Bandera - Claim 21 is obvious over the combination of five references.

• Prior Art Relied Upon: Neibauer, Cheng, Squibbs, Ausems, and Bandera (Patent 6,332,127).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground builds directly on Ground 1 to address dependent claim 21, which requires that "additional content" inserted based on location information comprises "advertising content." Petitioner argued that Bandera teaches a technique for selecting and delivering advertisements to a mobile user based on their physical location. The combination would result in a system where the club photo sharing page not only displays the photo and its location on a map (from Squibbs) but also includes location-based advertisements (from Bandera).
  • Motivation to Combine: The primary motivation for adding Bandera's teachings was commercial: to increase revenue. As Neibauer already disclosed placing advertisements on its club pages, a POSITA would find it obvious to enhance this feature by using the location-based targeting taught by Bandera to deliver more relevant and effective advertising.
  • Expectation of Success: Implementation was straightforward, as placing advertising on webpages was a well-known practice, and Bandera's method provided a clear model for doing so based on location.

• Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 3-4) based on the primary combinations but adding Harvey (Patent 6,487,583). This was done to preemptively address a potential claim construction of "application-based information channel" from a related litigation.

4. Key Claim Construction Positions

• "Wireless Networking Functionality" / "Wireless Network": Petitioner highlighted a dispute from related litigation over whether these terms require functionality "independent of the Internet." Patent Owner previously argued for this narrower construction. Petitioner contended that the asserted prior art combinations render the claims obvious even under this narrower construction, as geotracking data from GPS satellites (taught by Squibbs) is obtained independently of the internet. However, Petitioner maintained that the patent's own specification does not require the wireless network to be separate from the Internet.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv Factors): Petitioner argued against discretionary denial, stating the petition presents a compelling unpatentability challenge. It noted that the co-pending district court case is in its early stages, with a trial date of April 20, 2026, well after the PTAB's deadline for a Final Written Decision, minimizing concerns about parallel proceedings.
• §325(d): Petitioner asserted that denial under §325(d) is inappropriate because none of the asserted prior art references were cited or applied during the original prosecution of the ’039 patent, and they are not substantially the same as art previously considered by the USPTO.
• General Plastics: Petitioner argued that the petition should not be denied as an improper serial petition. It stated there is no "significant relationship" with a prior petitioner (Meta Platforms, Inc.) in a separate IPR against the same patent, and the accused products and asserted claims in the respective district court cases differ.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 8-9, 13-15, 17-25, and 28-30 of the ’039 patent as unpatentable.