PTAB

IPR2014-00153

Adobe Systems Inc v. AfLuo LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Streaming Multimedia Data
  • Brief Description: The ’091 patent describes a system for creating, streaming, and presenting multimedia data. The system uses three main components: an authoring tool to define a presentation, an interleaver to build a data stream from multimedia elements, and a playback interpreter to present the content on a client computer.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4, and 6-12 are anticipated by Cruz under 35 U.S.C. §102

  • Prior Art Relied Upon: Cruz (Patent 5,594,911).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cruz discloses every limitation of the challenged claims. Cruz teaches a system for preprocessing and delivering multimedia presentations that are composed of objects like images and sounds. An "Original Multimedia Presentation" (OMP) in Cruz, which lists data objects and their presentation times, corresponds to the ’091 patent’s "list specifying a plurality of data elements." Petitioner asserted that Cruz's "presentation technology parameters" (PTPs), which specify the "minimum bit rate of the distribution network" and "maximum memory capacity of the presentation processor," directly teach the limitation of "selecting a playback bandwidth." Cruz further describes a preprocessor that analyzes the OMP and PTPs to create a delivery schedule, repackaging objects into smaller portions if needed, which anticipates the limitations of identifying, dividing, and combining data portions into a multimedia stream. For claims related to interactivity (e.g., claim 6), Petitioner contended that Cruz’s "interaction table," which defines user-selectable interactive features and is sent as part of the data stream, anticipates the "conditional input statement appended to...data portions."

Ground 2: Claim 5 is anticipated by Rohatgi under 35 U.S.C. §102

  • Prior Art Relied Upon: Rohatgi (Patent 5,625,693).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rohatgi, which describes an interactive TV system that repeatedly transmits an audio-video-interactive (AVI) program, anticipates every element of claim 5’s method for regenerating a replayable data stream. Petitioner mapped Rohatgi’s use of a "module version number" for each data module in the program to the ’091 patent’s "level indicators." In Rohatgi, these version numbers are created when the AVI stream is generated and are stored in a directory module. When a receiver gets new program packets, it compares the incoming version number ("current level indicator") with the stored version number ("original level indicator") to identify updated modules. If a module has changed, the receiver locates the old version in memory and replaces it with the new, updated version. Petitioner asserted this process of identifying, comparing, locating, and replacing modules based on version numbers directly corresponds to the steps of regenerating a data stream recited in claim 5.

4. Key Claim Construction Positions

  • "selecting a playback bandwidth" (claim 1): Petitioner proposed this term should be construed as "specifying the transfer throughput of the distribution network and the available memory on the playback system within which data representing images or sounds are to be buffered." Petitioner argued this construction is necessary because the ’091 patent’s specification treats "bandwidth" as a composite property of both network throughput and the playback device's buffering capacity, both of which are required to determine if data can be delivered in time for playback.
  • "receiving a conditional input statement appended to one or more of said data portions" (claim 6): Petitioner proposed this term means "receiving a data portion, appended into a playback data stream with one or more other data portions...identifying run-time operator input that will vary the playback processing of the data stream." The key aspect of this construction is that "appended to" means incorporating the conditional statement into the data stream alongside other data objects, not physically attaching it to a specific media data object. Petitioner supported this by citing the ’091 patent’s description and file history, which clarify that conditional statements are independent objects added to the overall stream.
  • "means for..." (claims 9-12): Petitioner provided proposed constructions for numerous means-plus-function terms, identifying corresponding structures in the ’091 patent’s specification. For example, for the "means for generating a list" (claim 9), the structure was identified as the "authoring tool element." For the "means for combining said data portions" (claim 9), the structure was identified as the "interleaver element."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1 and 4-12 of the ’091 patent as unpatentable under 35 U.S.C. §102.