PTAB

IPR2025-01160

LiveIntent Inc v. AlmondNet Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Stored Program for Accumulating Descriptive Profile Data Along with Source Information for Use in Targeting Third-Party Advertisements
  • Brief Description: The ’904 patent discloses a method for a central computer system to collect and aggregate "partial profiles" of internet users from multiple, unaffiliated third-party websites. This aggregated data forms a maintained, composite profile that is then used to target third-party advertisements to the user's computer.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-11, 13-17, 19-21, 23-27, and 29-30 are obvious over Robinson in view of Jaye.

  • Prior Art Relied Upon: Robinson (Patent 5,918,014) and Jaye (Patent 6,415,322).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Robinson disclosed a central advertising system that tracks user web activity via code ("Smart Ad Box") on participating websites to build user profiles for targeted advertising. This system used a central database and tracking scripts to monitor user visits and interests. Petitioner asserted that Jaye disclosed a distributed network architecture where local servers (controlled by different entities) create local user profiles, and a central enterprise server compiles these into a global user profile. Jaye taught using URL redirection and pixel tags to link local user identifiers with a global user identifier stored in a cookie, enabling the enterprise server to receive and aggregate profile data from disparate sources. Petitioner contended the combination taught all limitations of independent claim 1, including a central system receiving a "URL-redirected partial profile" (Jaye's local profile) from an unaffiliated third-party server and automatically adding it to a "maintained profile" (Robinson's global profile).
    • Motivation to Combine: Petitioner argued a POSITA would combine Jaye's distributed identification and tracking scheme with Robinson's advertising system to remedy deficiencies in Robinson. This would empower Robinson's third-party "host machines" to create and use their own local profiles for site-specific content tailoring, while simultaneously contributing richer, more diverse data to the central system's global profile. The combination would result in more effective targeted advertisements, a key goal of both references.
    • Expectation of Success: Petitioner asserted a high expectation of success, as Robinson and Jaye disclosed analogous network architectures (a central system interacting with multiple third-party servers), employed common web technologies (cookies, URLs, tracking scripts), and shared the goal of profiling users based on web activity.

Ground 2: Claims 7-9, 17-19, and 27-29 are obvious over the Robinson-Jaye combination in view of Coleman.

  • Prior Art Relied Upon: Robinson (Patent 5,918,014), Jaye (Patent 6,415,322), and Coleman (Application # 2002/0026351).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Robinson-Jaye combination by adding the teachings of Coleman. Petitioner argued that Coleman disclosed a system for creating user profiles, verifying the gathered information for accuracy, and selling the verified information to advertisers. Coleman taught that the value and price of profile information increased with its verifiability. Petitioner mapped these teachings to the challenged dependent claims, arguing that Coleman’s verification process taught maintaining a "credibility rating" for profile attributes (claim 7). This credibility, in turn, was "reflected in a price" for the data (claim 8), and advertisers could select high-value attributes "based on the source" of verification (claim 9).
    • Motivation to Combine: A POSITA would integrate Coleman's information verification and sales process into the Robinson-Jaye data aggregation system for clear commercial reasons. Verifying the collected profile data would increase its reliability, improve advertiser satisfaction with the targeting results, and allow the central system operator to charge more for higher-quality, verified data. This modification would enhance the commercial viability and effectiveness of the advertising system.
    • Expectation of Success: Petitioner argued the combination would yield predictable results. Applying a known business process (data verification and monetization) to a known data collection system (Robinson-Jaye) was a straightforward integration of compatible concepts. The similar goals and technical environments of the references would have provided a POSITA with a reasonable expectation of success.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 3-11, 13-21, and 23-30 of Patent 8,494,904 as unpatentable.