Although a fact specific inquiry, it may be obvious as here to replace the format of one type of identifier (e.g., a random but unique numerical identifier) with another type of identifier (e.g., a person’s name) when both achieve the same result (e.g., unique identification).
Background / Facts: The application on appeal here from rejection at the PTO describes a method for enticing customers to visit a merchant’s website by sending the customer a direct mailer or email that includes a personalized uniform resource locator (“URL”). The personalized URL contains a suffix that consists of the customer’s name, such that once the customer enters the personalized URL in a web browser, the webpage displays a custom promotional offer.
Issue(s): Whether it would have been obvious to replace a numerical but otherwise unique suffix as disclosed in the prior art with the customer’s name.
Holding(s): Yes. Although the court questioned the expansiveness of the Board’s claim construction, it ultimately agreed with the Board’s obviousness conclusion. “The use of a person’s name as a particularized suffix in a URL would have been obvious to a person of ordinary skill in the art from the [prior art’s] disclosure of a unique personal identification number as a suffix in a URL.”