Apple Inc v. Allani Ferid

1. Case Identification

• Case #: IPR2025-00857
• Patent #: 10,943,058
• Filed: April 24, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): Ferid Allani
• Challenged Claims: 1-27

2. Patent Overview

• Title: Accessing Information Sources and Services on the Web
• Brief Description: The ’058 patent discloses systems and methods for accessing web information. The invention localizes preliminary search steps by using a communication device that beforehand locally stores a plurality of selection pages organized in a tree menu structure, with each page containing icons to reduce network delays and simplify browsing.

3. Grounds for Unpatentability

Ground 1: Claims 24-26 are obvious over Rossmann in view of Himmel.

• Prior Art Relied Upon: Rossmann (Patent 6,119,155) and Himmel (Patent 6,037,934).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Rossmann taught a mobile communication device that downloads and locally stores "decks" of "cards" (selection pages) in a tree structure to navigate information, minimizing network traffic. These locally stored cards included selectable textual items ("selection icons") that allowed a user to navigate to other locally stored cards within the deck. However, Rossmann did not explicitly teach selection pages comprising both selection icons for local navigation and "direct access icons" for linking to remote websites. Himmel taught downloadable, locally stored "bookmark sets" containing hyperlinked URLs ("direct access icons") that provide users with direct access to specific websites or web actions (e.g., a "consumer hot list"). The combination thus rendered obvious a system with locally stored pages containing both types of icons.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Himmel's bookmark functionality with Rossmann's local navigation system to improve user experience. This combination would further Rossmann's stated goal of simplifying navigation and reducing network traffic by providing more immediate access to commonly used web functions without navigating through multiple local pages.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references related to simplifying web navigation on resource-constrained devices, and the underlying technologies were compatible (e.g., bookmarking was a well-known feature in browsers, and Himmel's system was compatible with protocols like Rossmann's HDML).

Ground 2: Claims 1, 2, 4-6, 10-23, and 27 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: This ground built upon the Rossmann and Himmel combination, which established the core system of locally stored pages with both selection and direct access icons. The addition of King was alleged to render obvious the limitation that the address for a remote site is "locally generated" on the device. King taught an inline variable management method for the HDML environment where user selections on a mobile device dynamically update variables that are then substituted into a URL template, thereby "generating" the final URL locally before it is transmitted over the network.
  • Motivation to Combine: A POSITA would be motivated to incorporate King's local URL generation technique into the Rossmann/Himmel system to achieve the benefits described in King. Specifically, this technique solves the problem of client-state management without requiring a "server round-trip," which directly aligned with the ’058 patent's objective of reducing network latency and traffic.
  • Expectation of Success: Success was expected because Rossmann and King shared an assignee, described similar HDML architecture, and were built on the same HDML 2.0 specification. Applying King’s well-known URL generation method to the combined Rossmann/Himmel system would have been a straightforward implementation for a POSITA.

Ground 3: Claims 1, 2, 4-6, 10-23, 25, and 27 are obvious over Rossmann, Himmel, King, and Adar.

• 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 for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative to address the limitation of an icon "for directly accessing a search engine on the Web." Should the Board find that the "search" icon taught by Himmel was insufficient, Petitioner argued that Adar provided an explicit teaching. Adar disclosed a bookmark system that could download popular bookmarks to a user, and explicitly identified "Yahoo!" as an example of a popular bookmark for a search engine.
  • Motivation to Combine: A POSITA would have been motivated to add a popular search engine bookmark from Adar to the "consumer hot list" from Himmel. This would provide users with a general web search option if the specific information they sought was not available through the pre-defined local menus or direct action links, enhancing the overall utility and user-friendliness of the system.
• Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 3, 7-9 based on the combination of Rossmann, Himmel, King, and Boyle (or alternatively Adar), where Boyle (Patent 6,138,158) was cited for its teachings on updating locally stored pages when web content changes.

4. Key Claim Construction Positions

• "icon": Petitioner argued that, for the purpose of the IPR, the term "icon" should be construed to include textual icons (e.g., text-based hyperlinks). This position was based on the Patent Owner's infringement contentions in parallel district court litigation, where textual elements were accused of being "icons." This construction was critical to mapping prior art like Rossmann, which disclosed selectable text in menus.
• "specifically designed to include": Petitioner proposed that the Board adopt the Patent Owner's interpretation from the parallel litigation, construing this phrase to mean "used to include." This interpretation simplified the invalidity analysis by focusing on the function of the selection pages during operation rather than requiring evidence of an original design intent.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on the Fintiv factors was not warranted. The parallel district court litigation was in its nascent stages, with no substantive orders issued, discovery not yet open, and the trial date uncertain. Petitioner asserted that there had been little investment in the litigation and that the IPR petition challenged a broader set of claims than those asserted in the district court, favoring institution to promote efficiency.

6. Relief Requested

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