PTAB

IPR2025-01061

TikTok Inc v. DiStefano Website Innovations LLC

Key Events

Petition

petition

Title: Method for creating reciprocal hyperlink arrangements between websites.
Brief Description: The ’316 patent describes a server-based method allowing a user to create a first website, select a second, previously-created website, and generate a hyperlink from the first to the second. The system then automatically modifies the second website to include a reciprocal hyperlink back to the first.

Prior Art Relied Upon: Block (Application # 2003/0050976A1).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Block, a social media platform, discloses all limitations of the challenged claims. In Block, each user has a personal "My-Home mini-site" (first web site) that includes a "My-Friends list." This list contains hyperlinks to the mini-sites of other users (second web site). When a user accepts an invitation, a link to the inviting user's page is added to their own page, creating a reciprocal hyperlink. Petitioner asserted that Block’s interface for managing the friends list and editing site content meets the claimed graphical user interface (GUI) and editing screen limitations.
- Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner argued it would have been obvious to a person of ordinary skill in the art (POSITA) to implement the functionalities described in Block, as they represent well-known concepts in social networking and website management from that era.
- Key Aspects: The argument focused on mapping the social networking paradigm of "friends" and linked profiles in Block directly onto the patent's claims of reciprocally linked websites.

Prior Art Relied Upon: Arnold (Patent 6,016,504) and Arora (Patent 5,845,299).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Arnold discloses a system for a "virtual outlet" (VO) website (first web site) to sell a merchant's products. The VO site contains hyperlinks to the merchant's website (second web site), and the merchant site includes a "return" icon that functions as a reciprocal hyperlink back to the VO. This combination provides the core reciprocal linking structure. Arora discloses a "What You See Is What You Get" (WYSIWYG) webpage editor with a drag-and-drop GUI for creating and modifying web pages and assets.
- Motivation to Combine (for §103 grounds): A POSITA would combine Arnold’s e-commerce framework with Arora’s user-friendly WYSIWYG editor. Petitioner argued this would be a simple substitution of one known web editing interface for another to improve the ease of designing and managing the VO and merchant webpages described in Arnold. The combination would predictably result in a more efficient and user-friendly system.
- Expectation of Success: A POSITA would have had a high expectation of success, as combining a functional backend system (Arnold) with a standard GUI editor (Arora) was a common and well-understood practice in web development to improve usability.

Prior Art Relied Upon: Arnold (Patent 6,016,504), Arora (Patent 5,845,299), and Ahlberg (a 1992 conference paper on dynamic queries).
Core Argument for this Ground:
- Prior Art Mapping: This ground builds on the Arnold/Arora combination and adds Ahlberg to address limitations in claims 8 and 23, which relate to searching user information to select websites. Arnold discloses storing merchant and user information in a database. Ahlberg teaches using "dynamic queries" via a graphical interface to filter and search database information in real-time.
- Motivation to Combine (for §103 grounds): A POSITA would combine Ahlberg's dynamic query interface with the Arnold/Arora system to enhance the functionality for VO representatives. This would allow them to efficiently search a database of potential merchants based on specific criteria (e.g., business type), making it easier to find and establish new partnerships. This addresses the claimed feature of selecting websites by searching user information.
- Expectation of Success: The combination would yield predictable results. Applying a known database search interface (Ahlberg) to a system that stores user data in a database (Arnold) to improve searchability is a straightforward and predictable design choice.

"reciprocal link site": Petitioner dedicated significant argument to construing this term, which appears in dependent claims 13 and 26. Based on the claim language ("in the first web page"), the specification, and the prosecution history of a parent application, Petitioner argued that a "reciprocal link site" is not a separate website or webpage. Instead, it is properly construed as "a space within a webpage (within a website) for displaying reciprocal links to other websites." This construction is critical to finding the limitation met by elements like a friends list or a product display area within a single webpage in the prior art.

Petitioner argued that discretionary denial is not warranted, noting that under a recent USPTO memo (Director Stewart’s March 2025 memo), a separate, "bifurcated" briefing process exists for such issues. Therefore, Petitioner asserted it was not required to "pre-but" potential discretionary denial arguments within the petition itself.

Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 1-26 of the ’316 patent as unpatentable.