Personal Web Technologies, LLC v. Apple, Inc., No. 18-1599 (Fed. Cir. 2019)Annotate this Case
PersonalWeb’s patent explains that in conventional data processing systems, data items such as files are typically identified by their user-created alphanumeric name and/or pathname or location. Problems arise with traditional naming conventions if, for example, one device transfers a data item to a second device where the data item already exists so that a duplicate is created. The patent addresses that concern and others by creating a substantially unique identifier for each data item in the data processing system, independent of the data item’s user-defined name, location, etc., and dependent on only the content of the data item itself. The identifier for a particular data item is created by applying a cryptographic hash function to the data item. The output of the hash function is the content-based identifier or “True Name,” which is “virtually guaranteed” to be unique to the data item. In inter partes review, the Patent Board found that several claims were unpatentable as obvious in light of two prior art references. The Federal Circuit reversed. The Board relied on a “proposed, theoretical Binary Object Identifier look-up table” that does not necessarily exist in one of the references, so the Board’s reliance on inherency for that element in its obviousness analysis was improper.