PTAB

IPR2025-00856

Apple Inc v. Allani Ferid

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Device for Accessing Information- or Service-Providing Web Sites
  • Brief Description: The ’877 patent discloses systems and methods for accessing web-based information on a mobile device. The invention aims to be quicker than conventional browsing by localizing the initial search process on the device using a series of locally stored "selection pages" organized in a tree menu structure, which contain both icons for navigating between local pages and "direct access icons" for linking to external websites.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 9-15, and 17-19 are obvious over Rossmann, Himmel, and King.

  • Prior Art Relied Upon: Rossmann (Patent 6,119,155), Himmel (Patent 6,037,934), and King (Patent 6,353,839).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rossmann taught the core architecture of the ’877 patent, including a mobile device that minimizes network traffic by downloading and locally storing "decks" of "cards" (i.e., selection pages) organized in a hierarchical tree structure for local navigation. However, Petitioner contended Rossmann did not explicitly disclose selection pages containing both local navigation links ("selection icons") and direct-to-web hyperlinks ("direct access icons") on the same page. To supply this, Petitioner asserted Himmel taught downloadable, locally stored "bookmark sets" that function as direct access icons to specific URLs. Finally, to meet the "locally generated" address limitation, Petitioner pointed to King, which taught generating a URL on a mobile device by locally substituting variables based on user selections within an HDML environment.
    • Motivation to Combine: A POSITA would combine Rossmann and Himmel to improve usability and reduce network traffic, a goal shared by both references. Adding Himmel's "consumer hot list" of bookmarks to Rossmann's locally stored pages would provide users with a consistent interface and quick access to common web functions. A POSITA would further incorporate King's inline variable management to efficiently generate the required URL on the client device, thereby reducing server round-trips and network latency, which was a known problem King sought to solve.
    • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success, as bookmarking technology was well-known and the references described compatible systems based on a common HDML architecture. The combination represented the integration of known solutions to solve predictable problems.

Ground 2: Claims 7-8 and 16 are obvious over Rossmann, Himmel, King, and Boyle.

  • Prior Art Relied Upon: Rossmann (Patent 6,119,155), Himmel (Patent 6,037,934), King (Patent 6,353,839), and Boyle (Patent 6,138,158).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Rossmann, Himmel, and King to further address claims 7, 8, and 16, which recite updating the plurality of locally stored selection pages by downloading from a management server. Petitioner argued that while the primary combination established the base system, it did not expressly teach a mechanism for updating the locally stored content. Boyle was asserted to cure this deficiency by teaching a system where a mobile device with cached local content receives a notification from a web server when that content is updated, allowing the device to fetch and store the new information.
    • Motivation to Combine: A POSITA would be motivated to add Boyle's updating mechanism to the Rossmann-Himmel-King system to solve the known and significant problem of locally cached data becoming stale. Boyle expressly addressed this "great need" by providing an efficient method to update local content that saves costs and reduces unnecessary network traffic. A POSITA would seek to incorporate this functionality to make the base system more robust and useful.
    • Expectation of Success: Petitioner argued for a strong expectation of success because Rossmann and Boyle shared an inventor, were assigned to the same company, and described systems using a common HDML infrastructure. This shared technical foundation would have made the integration of Boyle's updating method into the Rossmann-based system straightforward for a POSITA.

4. Key Claim Construction Positions

  • For the purposes of the IPR, Petitioner proposed adopting the Patent Owner's constructions from parallel litigation.
  • A central contention was the construction of "icon." Petitioner argued that the Patent Owner's own infringement contentions in district court accused textual elements (e.g., "Playlists," "Artists," "Albums") of being "icons." Therefore, Petitioner asserted that any construction of "icon" must encompass textual icons, not just pictorial symbols. This position was critical to Petitioner's argument, as the prior art menus in Rossmann were primarily text-based lists.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigation was in its "nascent stages." Key factors cited included that claim construction was still ongoing, substantive discovery had not yet begun, and final invalidity contentions were not due for over a year. Petitioner contended that these factors, combined with the petition's high likelihood of success, strongly favored the Board exercising its discretion to institute the IPR.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’877 patent as unpatentable.