PTAB

IPR2025-00958

Maplebear Inc v. Fall Line Patents LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Data Management
  • Brief Description: The ’748 patent discloses a method for managing data collected from electronic forms or questionnaires. The system involves automatically sending these forms to handheld computing devices, which can operate in a "loosely networked" environment tolerant of intermittent internet connections, and synchronizing user responses with a central server.

3. Grounds for Unpatentability

Ground 1: Obviousness over Barbosa-Falls - Claim 7 is obvious over Barbosa in view of Falls.

  • Prior Art Relied Upon: Barbosa (Patent 6,961,586) and Falls (Patent 5,991,771).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Barbosa taught the majority of claim 7’s limitations, including a system for designing and wirelessly transferring an executable questionnaire to a handheld device with integrated GPS, using the GPS to gather location data, and transmitting responses back to a server in real-time. Falls was argued to supply the missing element of a "loosely networked" architecture, as it explicitly disclosed a system for mobile devices that intermittently connect to a wireless network and synchronize data upon reconnection.
    • Motivation to Combine: A POSITA would combine Falls’s teachings with Barbosa’s system to improve its functionality and expand its accessibility. The combination would allow Barbosa's questionnaire system to be used reliably by devices with intermittent connectivity, which was a known problem in mobile computing and represented a predictable improvement.
    • Expectation of Success: A POSITA would have a high expectation of success, as combining a known method for handling intermittent connections (Falls) with a networked application (Barbosa) involved routine programming and network configuration to achieve a predictable result.

Ground 2: Obviousness over Barbosa-Bandera - Claims 3-4, 9-11, and 13-15 are obvious over Barbosa alone or in view of Bandera.

  • Prior Art Relied Upon: Barbosa (Patent 6,961,586) and Bandera (Patent 6,332,127).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that independent claim 9 is substantially similar to other claims of the patent family previously found unpatentable over the same art, and thus collateral estoppel should apply. Regardless, Petitioner argued Barbosa taught all limitations of claim 9, including establishing communications with a GPS-enabled handheld device, transmitting location information, and receiving a questionnaire. The key limitation of a "tokenized questionnaire comprising a plurality of device indifferent tokens" was argued to be taught by Barbosa’s disclosure of using JAVA, which is inherently object-oriented (tokenized) and device-independent. Bandera was cited as an alternative to explicitly teach that JAVA code provides device-indifferent functionality.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Bandera with Barbosa to ensure Barbosa's questionnaire application was portable and could run on a wide variety of devices without modification. This addressed the known challenge of software compatibility and was a straightforward application of JAVA's primary benefits, as taught by Bandera.
    • Expectation of Success: Success was predictable, as implementing an application in JAVA (as suggested by Barbosa) to achieve device independence (as taught by Bandera) was a well-understood and common practice at the time.

Ground 3: Obviousness over Barbosa-Falls-Torrance Combination - Claim 8 is obvious over Barbosa in view of Falls and Torrance.

  • Prior Art Relied Upon: Barbosa (Patent 6,961,586), Falls (Patent 5,991,771), and Torrance (Application # 2002/0107726).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the combination for claim 7. Petitioner asserted that the Barbosa-Falls combination teaches all limitations of the base claim 7. Torrance was argued to teach the additional limitation of dependent claim 8: "assessing a charge for each transferred response received by said central computer." Torrance disclosed a survey system where commercial clients pay a "small fee per response" to gather customer preference data.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the business method taught in Torrance with the technical system of Barbosa-Falls for the simple and predictable purpose of monetizing the data collection service. Applying a fee-per-response model to a survey system was a known business practice to generate revenue.
    • Expectation of Success: Combining a known monetization strategy with a data collection system would have been a routine business and programming task with a predictable commercial outcome.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges. These grounds relied on similar core arguments but introduced other references to teach specific limitations, including Heath (Patent 6,006,034) for automatic program updates, Short (WO 00/31666) for making responses available via an internet website, Morris (Patent 6,460,138) for user authentication, Pinera (Patent 7,171,661) for real-time application updates, and Hamlin (Patent 6,477,504) for using a questionnaire design computer program.

4. Key Claim Construction Positions

  • Petitioner adopted claim constructions from prior PTAB and district court proceedings involving the ’748 patent. These constructions were central to the invalidity arguments:
    • "Loosely networked": "tolerant of intermittent network connections and tolerant of the type of network connection available." This construction was key to applying the Falls reference.
    • "Executable": "of, pertaining to, or being a program file that can be run." This supported the argument that Barbosa’s JAVA-based code was an executable questionnaire.
    • "Token": "a distinguishable unit of a program, such as an index, an instruction, or a command that can represent something else such as a question, answer, or operation." This construction was used to argue that Barbosa’s object-oriented program was inherently "tokenized."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 3-4 and 6-15 of Patent 9,454,748 as unpatentable.