Samsung Electronics Co Ltd v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2025-00537
• Patent #: 8,825,801
• Filed: February 3, 2025
• Petitioner(s): Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc.
• Patent Owner(s): Mobile Data Technologies LLC
• Challenged Claims: 1-25

2. Patent Overview

• Title: Techniques for information content management in network-based communications systems
• Brief Description: The ’801 patent describes methods and systems for managing information content in network-based communication systems. The technology focuses on allowing users, including unsophisticated ones, to create and manage content on mobile sites (termed "M-channels") accessible via mobile devices over wireless networks.

3. Grounds for Unpatentability

Ground 1: Claims 1-25 are obvious over Neibauer, Miller, Cheng, and Squibbs.

• Prior Art Relied Upon: Neibauer (a 2000 book, "How to Do Everything With Yahoo!"), Miller (WO 00/17775), Cheng (Patent 7,574,486), and Squibbs (Application # 2001/0015759).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of references taught every limitation of the challenged claims. Neibauer, the primary reference, disclosed Yahoo! Clubs, a service for creating web-based communities with features like message boards, photo sharing, and chat, which serve as the claimed "mobile information channel." Miller taught an interface for users to selectively choose which communication features to include in such a collaborative environment. Cheng disclosed a proxy server for converting standard web pages for optimal viewing on mobile devices. Finally, Squibbs taught associating photos with GPS location data and displaying them on a map, satisfying limitations related to location information.
  • Motivation to Combine: A POSITA would combine these references to meet predictable market demands. Neibauer's Yahoo! Clubs provided a strong base system for online communities. A POSITA would combine Miller to enhance the customizability of these clubs, allowing creators to select specific features (e.g., chat, photo sharing) to suit the community's purpose. Driven by the rapid growth of mobile internet access, a POSITA would integrate Cheng's well-known proxy server technology to make these club websites accessible to mobile users. To improve the photo-sharing feature, a POSITA would incorporate Squibbs's teachings to add valuable location context to shared photos, a natural extension suggested by Neibauer's own Yahoo! Maps feature.
  • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved applying conventional web technologies, known proxy server techniques, and existing GPS functionalities to established concepts of online communities.

Ground 2: Claims 1-25 are obvious over Neibauer, Miller, Cheng, and Squibbs in further view of Harvey.

• Prior Art Relied Upon: All prior art from Ground 1, plus Harvey (Patent 6,487,583).
• Core Argument for this Ground: This ground was presented to address a specific, alternative claim construction of "mobile information channel" proposed in co-pending litigation. This construction requires "a virtual location at the content management site at which user-authored content may be added for transmission to the mobile web site."
  • Prior Art Mapping: Harvey supplemented the Ground 1 combination by explicitly teaching a system where a community creator can author and add content to an online community before the community is formally launched and made available to other members. This pre-population of content satisfies the specific claim construction by disclosing the addition of user-authored content at the content management site stage.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Harvey with the prior art of Ground 1 to provide club founders with greater customizability and to improve the initial user experience for new members. Allowing a founder to pre-populate a club with content before launch ensures that members do not encounter an empty, unengaging site, thereby encouraging participation.
  • Expectation of Success: Success was expected because implementing a content pre-population feature was a straightforward extension of existing web-based community creation tools.

4. Key Claim Construction Positions

• "Mobile Information Channel": Petitioner contended this term does not require construction but demonstrated that the prior art meets the limitation under various constructions proposed in related litigation. These included Patent Owner's proposed "a component of a mobile site configured to permit a wide variety of mobile devices to send and receive content" and another party's proposed "a virtual location at the content management site at which user-authored content may be added."
• "Mobile Device": Petitioner disputed Patent Owner's proposed narrow construction ("a portable device with limited display space and limited navigational capabilities"), arguing it contradicts the patent's express definition, which includes devices like laptops.
• "Wireless Network": Petitioner argued against Patent Owner's proposed construction requiring a network that is "separate from the internet," asserting that the patent specification teaches the wireless network need not be separate and that the prior art discloses the limitation even under Patent Owner's improper construction (e.g., via a GSM network).

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv Factors): Petitioner argued against discretionary denial, asserting that the parallel district court case is in its very early stages. With trial scheduled for April 2026 and no claim construction hearing until late 2025, the PTAB’s Final Written Decision would issue long before any substantive court proceedings, promoting efficiency.
• §325(d) (Advanced Bionics): Petitioner argued that denial would be inappropriate. It noted that Miller, Squibbs, and Harvey were never considered by the examiner. While Neibauer and Cheng were cited during prosecution, the examiner's consideration was cursory and materially erred, as demonstrated by the successful reexamination of a parent patent that cancelled all claims based on the same references.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-25 of the ’801 patent as unpatentable.