Samsung Electronics Co Ltd v. Mobile Data Technologies LLC

1. Case Identification

• Case #: IPR2025-00543
• Patent #: 9,619,578
• Filed: February 5, 2025
• Petitioner(s): Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc.
• Patent Owner(s): Mobile Data Technologies LLC
• Challenged Claims: 1-19, 21-22

2. Patent Overview

• Title: Information Content Management in Network-Based Communications Systems
• Brief Description: The ’578 patent describes techniques for managing information content in network-based communication systems. The disclosed system allows users, including those on mobile devices, to author and share content via collaborative online communities or workspaces, referred to as "M-channels."

3. Grounds for Unpatentability

Ground 1: Obviousness over Neibauer, Cheng, Ausems, and Squibbs - Claims 1-19 and 21-22 are obvious over Neibauer in view of Cheng, Ausems, and Squibbs.

• Prior Art Relied Upon: Neibauer (a 2000 book, "How to Do Everything With Yahoo!"), Cheng (Patent 7,574,486), Ausems (Patent 6,434,403), 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 taught web-based communities ("Yahoo! Clubs") where users could create albums and share photos with associated text. Cheng taught a proxy server for adapting such standard web content for mobile devices. Ausems disclosed a mobile device (a PDA/phone combination) with an integrated camera capable of capturing and transmitting images. Finally, Squibbs taught integrating captured photos with location data (e.g., from GPS) and displaying the geotagged photos on a map-based interface.
  • Motivation to Combine: A POSITA would combine these references to meet the clear market demand for mobile access to web services. It would have been a logical and obvious step to use Cheng's proxy server technology to make Neibauer's "Yahoo! Clubs" accessible on the increasingly popular handheld mobile devices. Further, a POSITA would be motivated to enhance this service by allowing users to upload media captured directly by their mobile device's camera (per Ausems) and to integrate location data with photos (per Squibbs) to improve user experience, content classification, and context. Neibauer's disclosure of "Yahoo! Maps" further suggested the natural integration of map-based features like those in Squibbs.
  • Expectation of Success: A POSITA would have had a high expectation of success in combining these elements. The combination relied on the application of known technologies—such as proxy servers for content adaptation and GPS for location data—to existing web platforms to extend their functionality to mobile users, a common and predictable evolution in the art at the time.
• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1-19 and 21-22 based on the combination of Neibauer, Cheng, Ausems, Squibbs, and Harvey (Patent 6,487,583). Harvey was added solely to address a potential claim construction of "application-based information channel" from a related litigation, by teaching the ability to add user-authored content to an online community before the community is created and launched.

4. Key Claim Construction Positions

• "Mobile Device": Petitioner argued against the Patent Owner's proposed narrow construction from a related inter partes review (IPR), which would exclude conventional laptops. Petitioner contended that the plain meaning and the patent's own specification, which explicitly lists "a laptop computer" as an example of a mobile device, should control. This broader construction allows Neibauer's teachings related to laptops to directly apply.
• "Application-Based Information Channel": Petitioner argued that this term should be understood as a computer program-based medium for transferring information, consistent with its plain meaning and use in the patent. Petitioner contested different constructions proposed by the Patent Owner in related proceedings, asserting the prior art satisfies the claim limitations under any reasonable construction. The primary ground addresses the plain meaning, while the secondary ground with Harvey addresses a narrower construction proposed by another party in co-pending litigation.
• "Wireless Networking Functionality": Petitioner disputed the Patent Owner's position that this requires functionality "independent of the Internet." Petitioner argued the patent's specification allows for a wireless network that is not separate from the Internet. Furthermore, Petitioner contended that even under the Patent Owner's narrower construction, the combination meets the limitation through Squibbs's disclosure of using GPS signals, which are independent of the Internet, to obtain location data.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv Factors): Petitioner argued against discretionary denial based on a co-pending district court case, asserting the litigation was in its very early stages. Key events like the claim construction hearing (October 2025) and trial (April 2026) were scheduled well after the statutory deadline for a Final Written Decision (FWD) in the IPR, minimizing concerns of inefficiency and duplicative efforts.
• §325(d) (Advanced Bionics): Petitioner contended that denial would be inappropriate because key prior art (Squibbs and Harvey) was never considered by the examiner during prosecution. While Neibauer and Cheng were cited in an Information Disclosure Statement, Petitioner argued the examiner materially erred in failing to use them to reject the claims, pointing out that the PTO later relied on these same references to cancel all claims of a parent patent during reexamination.
• Serial Petitions (General Plastics): Petitioner asserted that this petition is not an improper serial petition. It argued there is no "significant relationship" or joint defense agreement between Petitioner (Samsung) and the petitioner (Meta) in a separate IPR against the same patent, and that the functionality of the respective accused products differs.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-19 and 21-22 of Patent 9,619,578 as unpatentable.