PTAB

IPR2026-00235

X Corp v. Search Share Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Web-Search System with User-Provided Input
  • Brief Description: The ’744 patent is directed to a web-search system where search results are generated based on user-provided input. The system allows a user to submit an identification of web content (e.g., a URL) along with user-generated content, such as keywords, ratings, or comments, to a server via a user interface that is separate from the main browser window. The server indexes this content to influence subsequent search results for other users.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5-6, 8-12, 14-15, and 17-19 are anticipated by or, in the alternative, obvious over Palmon.

  • Prior Art Relied Upon: Palmon (Application # 2006/0059134).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Palmon discloses every limitation of the challenged claims. Palmon teaches a topic-guided web search system where a user can associate a URL with a "topic" (e.g., a keyword) to create an "attachment." This attachment is transmitted to a server from a user interface, described as a "user-specific explorer bar (or other additional window)," which is separate from the "main display area" showing the web content. The server receives and indexes this information by creating an association between the URL and the topic for inclusion in future searches. Palmon further discloses a multi-user environment where a second user's search results include attachments created by a first user and other users, thereby showing the claimed "position relative to identifications of other web content."
    • Motivation to Combine (for §103 grounds): To the extent any minor difference exists, Petitioner argued a person of ordinary skill in the art (POSITA) would have found it obvious to make routine modifications to Palmon's system to arrive at the claimed invention, such as implementing its system on separate client computers for different users, which was a conventional design choice for client-server applications.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success as any modification would involve implementing known functionalities in a predictable manner.

Ground 2: Claims 1-19 are obvious over Palmon in view of Walther.

  • Prior Art Relied Upon: Palmon (Application # 2006/0059134), Walther (Application # 2005/0234891).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that to the extent Palmon's "explorer bar" is not considered a "user interface separate from the main browser window," Walther remedies this. Walther explicitly teaches collecting user annotations (ratings, keywords, comments) via an "annotation editing interface" that is displayed in a "separate window" from the subject page. Walther also teaches ranking search results based on an "aggregate rating" from every user who has provided a rating, addressing limitations in claims such as claim 4.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Walther's separate window interface with Palmon’s system because it represents a known, highly compatible, and user-friendly method for implementing the separate data entry function already contemplated by Palmon. Furthermore, a POSITA would be motivated to incorporate Walther's well-known technique of ranking results by aggregate user ratings into Palmon’s system to improve search result relevance and enhance the user experience.
    • Expectation of Success (for §103 grounds): Success was expected because combining the references would involve substituting one known UI element for another and applying a conventional search ranking algorithm to Palmon's existing data collection system, both being straightforward software implementations.

Ground 3: Claims 19 and 20 are obvious over Palmon in view of Walther and Lu.

  • Prior Art Relied Upon: Palmon (Application # 2006/0059134), Walther (Application # 2005/0234891), Lu (Application # 2005/0256866).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Palmon-Walther combination, which teaches collecting and displaying a querying user's own annotations. Petitioner asserted that Lu adds the teaching of presenting annotations from other users alongside search results. Lu discloses leveraging annotations from users within a "trust network" and displaying their comments next to search hits to provide socially informed context. This combination discloses the limitations of claim 19, which requires search results to comprise the user content associated with the web content, by showing how annotations from multiple users (including the first user who created the content) can be presented.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Lu's teachings with the Palmon-Walther system to further enhance the user experience. Displaying annotations from other users provides valuable social context and improves a user's ability to evaluate search results, a goal shared by all three references. Lu's approach was argued to be a natural and predictable extension of the annotation-display framework already present in the Palmon-Walther combination.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because implementing Lu's functionality would only require retrieving existing annotations from other users—data already collected in the Palmon-Walther system—and displaying them, a routine software modification.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of the ’744 patent as unpatentable.