PTAB

IPR2013-00054

Wowza Media Systems LLC v. Adobe Systems Inc

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1. Case Identification

2. Patent Overview

  • Title: Imparting Real-Time Priority-Based Network Communications In An Encrypted Communication Session
  • Brief Description: The ’287 patent discloses a method for encrypting communications between a server and a client by inserting "cryptographic information" into a pre-defined portion of a network handshake that is otherwise reserved for random data. The technology is described in the context of the Real Time Messaging Protocol (RTMP) for processing, transmitting, and re-assembling multimedia streams.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5, 6, 10, 12-14, 16, 17, 21, 23-26, 28, 29, and 33 are obvious over Edelman and Toth in view of Hellman.

  • Prior Art Relied Upon: Edelman (Patent 7,272,658), Toth (a 2007 article on RTMP connections), and Hellman (Patent 4,200,770).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Edelman and Toth (the "RTMP References") collectively disclose all limitations of the challenged claims except for those related to encryption. Specifically, they teach a real-time, priority-based communication system (RTMP) that uses a client-server handshake containing a section with random data, as well as the claimed methods for parsing and processing multimedia streams into chunks. Petitioner contended that Hellman, a foundational patent on public-key cryptography, teaches the missing elements: establishing a secure communication session by exchanging cryptographic information between a client and server to generate a cryptographic key for encrypting and decrypting messages.
    • Motivation to Combine: A POSITA would combine the well-known encryption methods of Hellman with the established RTMP protocol taught by Edelman and Toth to achieve the predictable result of secure media streaming. This combination would be motivated by the simple desire to add security to an existing, insecure protocol, a common design goal. Doing so by using a pre-existing part of the handshake would also improve efficiency by avoiding additional handshake messages.
    • Expectation of Success: Petitioner asserted success would be expected because the combination merely applies a known technique (encryption) to a known system (RTMP) to yield a predictable improvement (security).

Ground 2: Claims 1-3, 5, 6, 10, 12-14, 16, 17, 21, 23-26, 28, 29, and 33 are obvious over Edelman and Toth in view of Bousis.

  • Prior Art Relied Upon: Edelman (Patent 7,272,658), Toth (a 2007 article), and Bousis (Application # 2005/0129243).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground again relied on Edelman and Toth for teaching the underlying RTMP protocol. Petitioner argued that Bousis provides the specific teaching of hiding cryptographic information within random data to obfuscate it. Bousis discloses hiding an encrypted key in a header of a data exchange by replacing portions of random data with bits of the encrypted key. This, Petitioner argued, directly teaches the ’287 patent’s inventive concept of inserting cryptographic information into the portion of the RTMP handshake reserved for random data.
    • Motivation to Combine: A POSITA would combine Bousis’s technique with the RTMP protocol to not only encrypt the communication but also to obfuscate the key and the encryption method itself. The ’287 patent’s stated objective to "handicap reverse engineering attempts" aligns directly with the known steganographic principles taught by Bousis. This provided a strong motivation to implement encryption in this specific, covert manner.
    • Expectation of Success: A POSITA would have a high expectation of success in hiding a key within the random data section of the RTMP handshake, as Bousis teaches that its concepts are general and not limited to a specific protocol.

  • Additional Grounds: Petitioner asserted numerous other obviousness grounds based on the RTMP References (Edelman and Toth) in view of other art. These included combinations with Horman (teaching SSL/TLS encryption), Camp, Jr. (teaching insertion of cryptographic information into random data), Raike (inserting a key into a preexisting portion of a communication), and various "Information Hiding References" (Cole, Giffin, Lucena, Rowland, and Zander) that teach steganographic techniques for hiding data in network communications.

4. Key Claim Construction Positions

Petitioner argued that its invalidity analysis holds regardless of claim construction but proposed constructions for several terms disputed in parallel district court litigation.

  • "cryptographic information": Petitioner proposed "Secret information or information relating to the secret," arguing this is more specific than the Patent Owner’s proposed "Information for authenticating or encrypting." This construction emphasizes the covert nature of the information being inserted.
  • "reserved for random data": Petitioner proposed "Reserved for data produced in a manner where there was an equal or approximately equal probability for each possible value." This contrasts with the Patent Owner's "plain and ordinary meaning" and serves to define the specific nature of the handshake portion that is repurposed for hiding cryptographic information, making the teachings of prior art like Bousis more directly applicable.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-3, 5, 6, 10, 12-14, 16, 17, 21, 23-26, 28, 29, and 33 of the ’287 patent as unpatentable.