PTAB

IPR2025-01317

LiveIntent Inc v. Intent Iq LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Taking Action with Respect to One Network-Connected Device Based on Activity on Another Device Connected to the Same Network
  • Brief Description: The ’398 patent describes a method for delivering targeted advertisements to a second device (e.g., a television set-top box) based on user activity observed on a first device (e.g., a computer). The system establishes an association between the devices by automatically recognizing they are connected to a common local area network (LAN), typically by detecting a common IP address.

3. Grounds for Unpatentability

Ground 1: Obviousness over Eldering, POSITA Knowledge of IPv6, and Banga - Claims 1-4, 6-18, and 20-44 are obvious over Eldering, the general knowledge of a person of ordinary skill in the art (POSITA) regarding IPv6, and Banga.

  • Prior Art Relied Upon: Eldering (Application # 2002/0123928), Banga (Application # 2006/0265507), and a POSITA’s knowledge of Internet Protocol version 6 (IPv6) as evidenced by publications such as RFC 2460, RFC 3177, RFC 3513, and RFC 3587.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Eldering, discloses the core concept of the challenged claims: a system for targeting advertisements by creating subscriber profiles. Eldering specifically teaches creating "household" profiles that compile viewing and internet surfing data from multiple devices within a single home, such as a computer and a set-top box. However, Eldering suggests using identifiers like an IP address to associate devices with a household but does not specify a precise method for doing so when the profiling server is remote. Petitioner asserted that a POSITA’s knowledge of IPv6 would have supplied this missing implementation detail. A POSITA would have known that an IPv6 address contains a "global routing prefix" that is unique to a specific local network (e.g., a household LAN) and is common to all devices connected to it. This prefix provides a reliable mechanism for "automatically recognizing" that devices are on the same LAN. The secondary reference, Banga, was introduced to address the use of cookies. Banga teaches a hybrid "cookie/device identifier" system to improve tracking robustness, particularly when a device moves between networks and its IP address changes. This combination allegedly renders the limitations of the independent claims obvious.
    • Motivation to Combine: Petitioner contended that a POSITA seeking to implement Eldering’s household profiling system would have needed a reliable way to associate devices with a particular household. Using the well-known global routing prefix of an IPv6 address was an advantageous and predictable solution to this known problem. Eldering provides the "why" (build a household profile), and IPv6 provides the "how" (use the common address prefix to link devices). A POSITA would further combine Banga to make the system more robust and compatible with existing cookie-based advertising systems. Adding Banga's teachings on hybrid cookie/identifier tracking would be a simple, obvious improvement to better track devices across different networks.
    • Expectation of Success: Petitioner argued that a POSITA would have had a high expectation of success. The proposed combination involves nothing more than applying known solutions (IPv6 address structures, cookie-based tracking) to solve known problems (associating devices, robust tracking) in the predictable field of network-based targeted advertising. The fundamental system of Eldering remains intact, merely enhanced with well-understood technologies to achieve the claimed invention.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-4, 6-18, and 20-44 of the ’398 patent as unpatentable.