Samsung Electronics Co Ltd v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2025-00540
• 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: 1-3, 6-16, 19-21, 23-27

2. Patent Overview

• Title: Techniques for Information Content Management in Network-Based Communications Systems
• Brief Description: The ’336 patent relates to techniques for managing information content within network-based communication systems, focusing on methods for users of mobile devices to access and share content over wireless networks.

3. Grounds for Unpatentability

Ground 1: Obviousness over Randall and Forsyth - Claims 1-3, 6-16, 19-21, and 23-27 are obvious over Randall in view of Forsyth.

• Prior Art Relied Upon: Randall (WO 02/17652) and Forsyth (Patent 7,047,030).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Randall disclosed the foundational "Forums" service, a network infrastructure for mobile devices featuring a client-server model, an extensible database, and user access via WAP or HTTP. Forsyth disclosed specific enhancements to this exact "Forums" service, particularly the use of application-independent "group objects" to improve group communication and add features. Petitioner contended the combination taught the claimed method where a "first web-based interface" (e.g., a "New Forum" user interface in Forsyth) is used to activate a "mobile information channel" (the Forum itself). A "second web-based interface" is then generated to provide other users with access to shared content within that channel.
  • Motivation to Combine: A POSITA would combine the references because Forsyth explicitly described its "group objects" as an enhancement for the "Forums" service detailed in Randall. Both references were assigned to the same entity (Symbian Limited), operated in the same technical field, and were directed to solving the same problems in mobile content sharing. The combination represented a predictable improvement of a known system.
  • Expectation of Success: Petitioner asserted success would be predictable because both references were based on the well-known Symbian operating system and were designed to work together on the same "Forums" platform, ensuring technical compatibility.

Ground 2: Obviousness over Pelkey and Eck - Claims 1, 6-11, 13-16, 20-21, and 23-25 are obvious over Pelkey in view of Eck.

• Prior Art Relied Upon: Pelkey (Patent 7,056,217) and Eck (Patent 6,716,103).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Eck disclosed "PagerWorld," a virtual community for portable game machines (e.g., Nintendo GameBoy) that functioned as the claimed "mobile information channel," allowing users to share messages, photos, and sounds. However, Eck primarily relied on a charge-based pager cartridge system for communication. Pelkey disclosed a superior client-server network architecture for enabling messaging between game systems over a wide area network like the Internet. Petitioner argued that combining these references would implement Eck’s "PagerWorld" features using Pelkey’s network. In this combination, Eck’s main game screen served as the "first web-based interface," and subsequent interfaces like the in-game address book or message center served as the "second web-based interface."
  • Motivation to Combine: A POSITA would combine the references to implement Eck's desirable gaming and social features ("PagerWorld") using Pelkey's more robust, flexible, and cost-effective Internet-based network architecture. This would have been a simple substitution of a known communication method (internet) for an inferior one (pager system) to gain predictable benefits.
  • Expectation of Success: Success was expected because both references were directed to the same product and activity (adding messaging capabilities to portable game systems). The disclosures were complementary, with Pelkey providing the network backbone that Eck’s application lacked.

4. Key Claim Construction Positions

• "Mobile Device": Petitioner disputed the Patent Owner’s narrow construction from a related case ("a piece of handheld equipment"). Petitioner argued for a broader construction consistent with the specification’s express definition, which includes any type of portable information processing device capable of network communication (e.g., mobile phone, PDA, laptop).
• "Mobile Information Channel": Petitioner argued that this term did not require express construction but demonstrated that the prior art met the limitation under various proposed constructions from related litigation, including "a medium for transferring information that allows mobile device users to author content."
• "Wireless Network": Petitioner disputed the Patent Owner’s proposed construction that required the wireless network to be "separate from the internet." Petitioner argued the prior art disclosed the claimed element under either its proposed broader construction or the Patent Owner's narrower one.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors would be inappropriate. The petition asserted it presents a compelling unpatentability challenge. It further noted that the parallel district court litigation is in its early stages, with minimal discovery conducted and a claim construction hearing not scheduled until after the statutory deadline for an institution decision in this inter partes review (IPR). Petitioner also argued against denial under §325(d), stating that the asserted prior art references were not previously considered during prosecution or reexamination.

6. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-3, 6-16, 19-21, and 23-27 of Patent 8,793,336 as unpatentable.