PTAB

IPR2025-01184

Pinterest Inc v. OpenTV Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Supporting Common Interactive Television Functionality Through Presentation Engine Syntax
  • Brief Description: The ’169 patent describes methods for presenting content, such as web pages containing audio, video, or graphics. The core concept involves using "prerequisite directives" within the content's code to control the rendering process, specifically by prohibiting the presentation until certain required resources are fully acquired.

3. Grounds for Unpatentability

Ground 1: Obviousness over Beri - Claims 1, 2, 22, and 23 are obvious over Beri

  • Prior Art Relied Upon: Beri (Patent 6,141,018).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Beri, which discloses a method for displaying animated images (a "marquee") in a hypertext document, teaches every limitation of the independent claims. Beri’s system uses an ActiveX object with parameters to control the animation. One such parameter, DrawImmediately, functions as the claimed "prerequisite directive." When this flag is set to disabled (VALUE=0), it prohibits the marquee presentation until all associated image resources are downloaded, thus meeting the core prohibition/acquisition steps of claim 1. When the flag is enabled, it is not a prerequisite directive, and the presentation initiates immediately, meeting the initiation step of claim 1.
    • Motivation to Combine (for §103 grounds): Not applicable, as this ground relies on a single reference. Petitioner asserted that Beri's disclosed embodiments would have been combined by a Person of Ordinary Skill in the Art (POSITA) to achieve the described marquee functionality.
    • Expectation of Success (for §103 grounds): A POSITA would have had an expectation of success in implementing the features, as Beri teaches an integrated system where the various components (marquee object, HTML viewer, computing system) are designed to work together.

Ground 2: Obviousness over Armstrong - Claims 1, 2, and 23 are obvious over Armstrong

  • Prior Art Relied Upon: Armstrong (a 1997 book titled Designing and Using ActiveX Controls).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Armstrong teaches a method for managing resources in web documents using ActiveX controls that renders the claims obvious. Armstrong distinguished between fully embedded resources and resources linked via a "data path property." Petitioner argued that embedded resources function as prerequisite resources; their presence acts as a prerequisite directive because Armstrong taught that a web browser will prohibit the presentation of the web page until these embedded resources are fully downloaded. In contrast, resources linked via a data path property are not prerequisites and allow for asynchronous, progressive rendering. This binary system of handling resources directly maps to the claim limitations of determining a prerequisite, prohibiting presentation if present, and initiating presentation if not.
    • Motivation to Combine (for §103 grounds): Not applicable, as this ground relies on a single reference. Petitioner argued a POSITA would combine Armstrong's teachings on ActiveX controls to address low-bandwidth environments and enable efficient progressive rendering.
    • Expectation of Success (for §103 grounds): A POSITA would have expected success in implementing the system, as Armstrong provides detailed instruction on using ActiveX controls, a well-documented and widely used technology at the time.

Ground 3: Obviousness over Beri in view of Harrington - Claims 3 and 22 are obvious over Beri in view of Harrington

  • Prior Art Relied Upon: Beri (Patent 6,141,018) and Harrington (Patent 7,120,871).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the teachings of Beri by adding Harrington to supply the limitations of dependent claim 3. Claim 3 requires that the directives are "received by a proxy server in an interactive television system." Harrington discloses an enhanced video programming system that integrates web content with television broadcasts. Petitioner asserted that Harrington explicitly taught the use of a remote web server, functioning as a proxy server, within the context of an interactive television system to retrieve and construct web pages for display to a user.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Beri’s animation rendering with Harrington’s interactive television system to improve the user experience by enabling the display of dynamic, animated web content on television. Both references solve problems related to rendering web pages and use similar software environments.
    • Expectation of Success (for §103 grounds): Success was expected because both systems were designed to operate in similar computing environments (e.g., Windows, web browsers), making the integration of Beri’s rendering method into Harrington’s television framework predictable.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including:

    • Combining Beri or Armstrong with Kunze (a 1999 memorandum on metadata) to teach the use of a META name/value pair as a prerequisite resource (claim 11).
    • Combining Beri or Armstrong with Del Sesto (Patent 7,069,571) to teach prohibiting presentation based on an expiration time and allowing it after expiration (claim 12).
    • Combining Armstrong with Harrington to provide an alternative basis for the invalidity of claims 3 and 22.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 11-12, and 22-23 of the ’169 patent as unpatentable.