PTAB

IPR2026-00330

Viant Technology LLC v. Intent Iq LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: METHOD AND COMPUTER SYSTEM USING PROXY IP ADDRESSES AND PII IN MEASURING AD EFFECTIVENESS ACROSS DEVICES
  • Brief Description: The ’962 patent describes systems and methods for correlating a user's online devices (ODs), such as computers and smartphones, with their set-top box (STB). This correlation allows television advertisements delivered to the STB to be targeted based on user profile information gathered from the associated online devices.

3. Grounds for Unpatentability

Ground 1: Obviousness over Shkedi-728 and Chamberlain - Claims 1-34 are obvious over Shkedi-728 in view of Chamberlain.

  • Prior Art Relied Upon: Shkedi-728 (Application # 2009/0172728) and Chamberlain (Application # 2010/0094758).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Shkedi-728, an application from the same inventor as the ’962 patent, discloses the foundational system for the challenged claims. This system includes a Central Ad Server (CAS) that associates a user's online device with their STB to enable targeted television advertising based on the user's online behavior. Shkedi-728 explicitly suggests that this association can be established using Personally Identifiable Information (PII) but does not detail a specific mechanism for doing so. Petitioner contended that Chamberlain supplies this missing detail. Chamberlain describes systems for matching third-party data with access providers' subscriber data, specifically teaching the use of PII such as names and email addresses to match disparate data sets associated with a single user.

    • Petitioner asserted that combining these references renders the independent claims obvious. For method claim 1, the combination teaches a computer system (Shkedi-728’s CAS) that stores an association between a first online device (OD1) and an STB. This is achieved by matching first PII about the OD1 user (e.g., name, email, and IP address from an ISP, as taught by Chamberlain) with second PII about the STB user (e.g., name and email from a television provider, also taught by Chamberlain). The combination further teaches measuring ad effectiveness by tracking user behavior on a second online device (OD2) after an ad is shown on the STB, a core purpose of Shkedi-728’s system. Petitioner argued that Shkedi-728, particularly through its incorporation of the Shkedi-906 application, discloses associating multiple devices (OD1 and OD2) that share a common "proxy IP address" (i.e., the modem's IP address), thus meeting further limitations. System claim 22 was argued to be obvious for the same reasons as method claim 1.

    • Petitioner also mapped the combination to numerous dependent claims. For example, features such as using a dynamically assigned IP address (claim 4), undoing an association after a period of inactivity (claim 5) or upon user opt-out (claim 6), and receiving PII from a television provider (claim 8) were all argued to be explicitly taught or suggested within Shkedi-728's detailed description of its advertising system and user privacy options.

    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would be motivated to combine the references to solve a known problem. Shkedi-728 identified the need to associate devices using PII but left the implementation open. Chamberlain provided a known, concrete technique for using subscriber PII to match disparate data sets. A POSITA would have found it obvious to apply Chamberlain's specific PII-matching solution to implement the general approach proposed in Shkedi-728's advertising system. Both references operate in the same technical field of online advertising data management, use similar infrastructure like centralized servers, and address the same problem of associating user identities across different platforms.

    • Expectation of Success: A POSITA would have reasonably expected success in implementing the combination. The integration involved applying a known data-matching technique (from Chamberlain) to a well-defined advertising system (from Shkedi-728) using conventional software and hardware. The techniques described in Chamberlain were fully compatible with the architecture disclosed in Shkedi-728.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-34 of the ’962 patent as unpatentable.