Apple Inc v. MyPort Inc

1. Case Identification

• Case #: IPR2025-01466
• Patent #: 10,237,067
• Filed: September 9, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): MyPort, Inc.
• Challenged Claims: 6-17

2. Patent Overview

• Title: System and Method for Capturing, Storing, and Using Content with Context Tags
• Brief Description: The ’067 patent discloses a system for capturing media content such as images and audio. The system processes the content to generate and associate searchable "context tags" derived from the content itself (e.g., through speech-to-text or image recognition) and from other metadata sources like time and location.

3. Grounds for Unpatentability

Ground 1: Claims 6-17 are obvious over Spatharis in view of Manjunath.

• Prior Art Relied Upon: Spatharis (Application # 2006/0227995) and Manjunath (a 2002 textbook, "Introduction to MPEG-7: Multimedia Content Description Interface").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Spatharis discloses all elements of the challenged claims. Spatharis describes a camera system that captures images and audio, stores them in an internal storage device, and uses a "metadata extraction engine" to analyze the content. This engine performs "speech to text conversion" on audio and "visual properties face recognition" on images to generate metadata "tags" and "annotations." Spatharis also teaches capturing collateral data like GPS location and time. Petitioner contended that the only missing element was ensuring the generated tags were organized in a text-based, searchable format. Manjunath, a well-known textbook on the MPEG-7 standard, remedied this by describing the "longstanding and widespread" practice of using text annotations (e.g., in XML format) to search, catalogue, and index multimedia content.
  • Motivation to Combine: A POSITA would combine these references to improve Spatharis’s system. Spatharis discloses that its extracted metadata can be stored in "one or more formats," which would have prompted a POSITA to look to known, standard formats. Manjunath describes the industry-standard MPEG-7 format for this exact purpose. A POSITA would combine the teachings to increase the utility of the captured media by making the metadata searchable and to ensure wide-ranging interoperability between devices, a recognized benefit of the MPEG-7 standard.
  • Expectation of Success: Petitioner asserted a high expectation of success because Manjunath is a textbook that provides a practical, step-by-step guide for implementing the MPEG-7 standard, ensuring the combination would yield predictable results.

Ground 2: Claims 6-17 are obvious over Fuller in view of Jain.

• Prior Art Relied Upon: Fuller (Patent 6,833,865) and Jain (Patent 7,295,752).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Fuller teaches a digital capture device (e.g., a video camera) with all the core components of independent claim 6: a camera for capturing images, a microphone for capturing audio, A/D converters (a "first data converter") for digitizing the audio, and internal storage (e.g., frame and sound buffers). Fuller also discloses capturing collateral metadata like GPS location and time. For generating context tags, Fuller teaches an "audio/video analysis engine" that performs "metadata extraction," such as face recognition on images. To supply the claimed speech-to-text conversion, Fuller explicitly incorporates Jain by reference as a suitable example implementation of its analysis engine. Jain describes a "speech transcription module" that uses speech recognition to convert a digital audio signal into a full-text transcription, satisfying the limitation of creating a text-based context tag.
  • Motivation to Combine: The motivation was explicit, as Fuller directs a POSITA to Jain for implementation details of its audio/video analysis engine. Petitioner argued this express incorporation by reference provided a clear and compelling reason to combine the teachings of the two references.
  • Expectation of Success: Success would have been reasonably expected because Fuller directs the combination, and it involves implementing a known technique (Jain's speech transcription) into a known system (Fuller's analysis engine) to achieve a predictable result (a system that creates both text and image-based metadata).
  • Key Aspects: Petitioner noted that the Board had previously instituted an inter partes review (IPR) against the ’067 patent based on Fuller, finding a reasonable likelihood of success on obviousness grounds before that proceeding settled.

4. Key Claim Construction Positions

• Petitioner argued that no terms require express construction for the IPR. However, it noted the following constructions from a prior district court litigation involving the ’067 patent, asserting the prior art teaches the limitations under either construction.
  • "context tag" (claims 6, 13): "a searchable element derived from either a data element itself or from the context description element"
  • "image source" (claims 13, 16): "an internal or an external image source"

5. Relief Requested

• Petitioner requests the institution of an inter partes review and cancellation of claims 6-17 of Patent 10,237,067 as unpatentable under 35 U.S.C. §103.