PTAB

IPR2025-00857

Apple Inc v. AlLANi Ferid

Title: Accessing Web Information and Services
Brief Description: The ’058 Patent describes systems and methods for accessing web content more quickly by localizing part of the browsing process. The invention uses a communication device with beforehand locally stored "selection pages" organized in a hierarchical tree menu, where pages contain both "selection icons" for local navigation and "direct access icons" for linking to remote websites.

Prior Art Relied Upon: Rossmann (Patent 6,119,155) and Himmel (Patent 6,037,934).
Core Argument:
- Prior Art Mapping: Petitioner argued Rossmann teaches the core features of the ’058 patent, including a mobile device that downloads and locally stores "decks" of "cards" (selection pages) in a hierarchical structure to reduce network traffic. These cards contain selectable textual icons that function as "selection icons" to navigate between other locally stored cards. Petitioner asserted Himmel teaches downloadable, locally stored "bookmark sets" containing hyperlinked URLs for common web actions (a "consumer hot list"), which function as the claimed "direct access icons."
- Motivation to Combine: A POSITA would combine Himmel's bookmark functionality with Rossmann's local navigation system to improve user experience by providing immediate access to common web actions. This would further the shared goals of both references to simplify navigation and reduce network traffic, particularly for unskilled users.
- Expectation of Success: A POSITA would have a high expectation of success, as bookmarking was a well-known technology. Integrating Himmel's bookmark manager software into Rossmann's existing architecture to store bookmarks in RAM alongside Rossmann's decks was argued to be a straightforward modification.

Prior Art Relied Upon: Rossmann (Patent 6,119,155), Himmel (Patent 6,037,934), and King (Patent 6,353,839).
Core Argument:
- Prior Art Mapping: This ground builds on the Rossmann/Himmel combination and adds King to teach the "address being locally generated" limitation (claim 1(c)(2)). Petitioner contended that while Rossmann/Himmel teaches the system of local pages with both selection and direct access icons, King teaches the specific mechanism for generating the address on the device. King discloses "inline variable management" in an HDML environment where a URL is modified locally on the device based on user selections before being transmitted.
- Motivation to Combine: A POSITA would combine King's teachings to solve the problem of using client state without a server round-trip, a benefit explicitly stated in King that aligns with the goals of Rossmann and Himmel. Given that Rossmann and King share an assignee and are built on the same HDML 2.0 architecture, the combination was presented as a logical and beneficial integration.
- Expectation of Success: Success was expected because King’s methods were described as elucidating processes already part of the HDML 2.0 specification, which is incorporated by reference into Rossmann, making the technologies highly compatible.

Prior Art Relied Upon: Rossmann (Patent 6,119,155), Himmel (Patent 6,037,934), King (Patent 6,353,839), and Adar (Patent 6,493,702).
Core Argument:
- Prior Art Mapping: This ground was advanced as an alternative, adding Adar to explicitly teach an icon for a "search engine" (claims 1(b) and 25) if the Board found the "search" icon in Himmel insufficient. Petitioner argued Adar teaches a bookmark system that can download popular bookmarks to a device, including a bookmark for the "Yahoo!" search engine.
- Motivation to Combine: A POSITA would add Adar's functionality to the base Rossmann/Himmel/King system to provide users with a convenient link to a major search engine. This would enhance the device's utility by allowing users to conduct broader searches if the desired content was not found within the locally stored pages.
Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 3 and 7-9 over the combination of Rossmann, Himmel, King, and Boyle (or alternatively Adar and Boyle), where Boyle was relied upon for its teachings on updating locally stored information.

For the purposes of the IPR, Petitioner proposed adopting the Patent Owner's positions from parallel litigation.
"icon": Petitioner argued the term must encompass "textual icons" (e.g., text-based hyperlinks), based on the Patent Owner's infringement contentions and intrinsic evidence from the ’058 patent.
"specifically designed to include": While maintaining the term is indefinite, Petitioner adopted the Patent Owner's construction of "used to include." Petitioner argued this requires more than mere capability, meaning the selection pages must, in operation, actually be used to contain the claimed icons.

Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors would be inappropriate.
The core argument was that the parallel district court litigation is in a nascent stage, with discovery not yet open and key deadlines for invalidity contentions and summary judgment briefs set for 2025 and 2026. Petitioner asserted that minimal investment has occurred in the litigation and that the IPR challenges numerous claims not at issue in the court case, favoring Board review.

Petitioner requests institution of an inter partes review and cancellation of claims 1-27 of Patent 10,943,058 as unpatentable.