Samsung Electronics Co Ltd v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2025-00539
• Patent #: 8,793,336
• Filed: February 7, 2025
• Petitioner(s): Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc.
• Patent Owner(s): Mobile Data Technologies LLC
• Challenged Claims: 1, 6-11, 13-18, and 20-27

2. Patent Overview

• Title: Information Content Management in Network-Based Communication Systems
• Brief Description: The ’336 patent describes network-based systems for managing information content, specifically focusing on techniques allowing users to create and share content via "mobile information channels" accessible by mobile devices over wireless networks.

3. Grounds for Unpatentability

Ground 1: Obviousness over Neibauer, Miller, and Cheng - Claims 1, 6-11, 13-18, and 20-27 are obvious over Neibauer in view of Miller and Cheng.

• Prior Art Relied Upon: Neibauer (a 2000 publication titled "How to Do Everything With Yahoo!"), Miller (WO 00/17775), and Cheng (Patent 7,574,486).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of these references teaches all limitations of the challenged claims. Neibauer was asserted to disclose the core functionality through its description of "Yahoo! Clubs," a service allowing users to create web-based communities with features like message boards, chat, and photo sharing. These features correspond to the claimed "mobile information channel." Miller was argued to supplement Neibauer by teaching a user interface that allows a creator to selectively choose which communication features (e.g., bulletin board) to include when creating a collaborative environment, thus teaching the "activation" of a given channel. Cheng was asserted to teach the mobile and wireless aspects, describing a proxy server that reformats existing web pages (like those for Yahoo! Clubs) for proper display on mobile devices, such as PDAs, over a wireless network.
  • Motivation to Combine: A POSITA would combine Neibauer with Miller to enhance the customizability of Yahoo! Clubs, allowing creators to tailor the features to their community's needs. The motivation to add Cheng was driven by strong market demand for mobile access to web content. Neibauer itself disclosed "Yahoo! Mobile" services, and Cheng provided a known "bolt-on" solution to make any web service, like Yahoo! Clubs, available to the growing number of mobile device users without needing to build separate mobile websites.
  • Expectation of Success: A POSITA would have had a high expectation of success as the combination involved applying standard web programming and known proxy server technology to existing web services to extend their functionality to mobile platforms.

Ground 2: Obviousness over Ground 1 Prior Art in View of Ausems - Claim 7 is obvious over Neibauer, Miller, and Cheng in view of Ausems.

• Prior Art Relied Upon: Neibauer, Miller, Cheng, and Ausems (Patent 6,434,403).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on Ground 1 to specifically address the limitation in claim 7 requiring shared content to be obtained from a "device-captured data source," such as "device-captured image data." While Petitioner argued Ground 1 implicitly taught this, Ausems was added to provide an explicit teaching. Ausems discloses a portable mobile device (a PDA combined with a wireless telephone) that includes an integrated digital camera for capturing and transmitting images.
  • Motivation to Combine: A POSITA would combine Ausems with the base combination to expand the functionality of the shared content platform. As users increasingly used mobile devices with integrated cameras, it would have been a natural and obvious improvement to allow them to capture images with their device and directly upload them to their online communities, as taught by Neibauer.

Ground 3: Obviousness over Ground 1 Prior Art in View of Fransioli - Claims 21-22 are obvious over Neibauer, Miller, and Cheng in view of Fransioli.

• Prior Art Relied Upon: Neibauer, Miller, Cheng, and Fransioli (Application # 2004/0198396).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground targets claims 21 and 22, which require "personalized messaging content" and the integration of "location-based service information." Fransioli was asserted to teach a system for delivering personalized content, such as advertising, to a mobile device based on its current location and direction of travel.
  • Motivation to Combine: A POSITA would combine Fransioli's location-based personalization with the base combination to enhance the user experience and provide more relevant content. Fransioli expressly motivates this by explaining that its system provides "localized and personalized information content in ways that improve over existing systems." Applying this to the Yahoo! Clubs context would allow for targeted announcements or ads relevant to a user's location to be displayed within the club's message board, an obvious improvement for both users and advertisers.

• Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 4-6) based on the combinations of Grounds 1-3 in further view of Harvey (Patent 6,487,583). Harvey was added primarily to address a potential claim construction of "mobile information channel" proposed in related litigation, by teaching the ability for a community creator to author and add content before the community is officially launched.

4. Key Claim Construction Positions

• "Mobile Device": Petitioner argued against Patent Owner's narrow construction from a related inter partes review (IPR) that would exclude laptops. Petitioner contended that the ’336 patent's specification expressly defines the term to include, without limitation, "a laptop computer," and therefore the plain meaning consistent with the specification should apply.
• "Wireless Network": Petitioner disputed Patent Owner's proposed construction that the "wireless network" must be "a network separate from the internet." Petitioner argued the patent specification contradicts this, and that even if the construction were adopted, the prior art combination (e.g., using a GSM network as taught by Neibauer) would still disclose such a separate 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 early stages, with trial not scheduled until April 2026 and no claim construction order expected before the institution decision.
• §325(d) (Prior Art Considered by Examiner): Petitioner argued that while Neibauer and Cheng were cited during prosecution, the Examiner materially erred by failing to rely on them to reject the claims. Petitioner noted that the PTO itself later relied on Neibauer and Cheng in a successful reexamination that cancelled all claims of a related patent to which the ’336 patent is terminally disclaimed.

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1, 6-11, 13-18, and 20-27 of the ’336 patent as unpatentable.