PTAB

IPR2014-00154

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 discloses a multimedia system for creating, streaming, and presenting multimedia presentations. The system uses three primary components: an authoring tool to define presentation elements and parameters, an interleaver to build a data stream, and a playback interpreter to present the content.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Little - Claims 1, 4, and 9-11 are anticipated by or obvious over Little.

  • Prior Art Relied Upon: Little & Ghafoor, “Multimedia Synchronization Protocols for Broadband Integrated Services,” IEEE Journal on Selected Areas in Communications (Dec. 1991) (“Little”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Little, a 1991 publication describing protocols for delivering multimedia content, discloses every limitation of claims 1, 4, and 9-11. Little’s system generates a list of media elements with playback times from an Object Composition Petri Net (OCPN), which corresponds to claim 1’s requirement for generating a list of data elements with specified playback times. Petitioner contended that Little’s use of “channel capacity” and calculation of required buffer size to create a delivery schedule inherently teaches selecting a playback bandwidth. Little also describes dividing media objects into packets for transmission over a packet-switched network and combining them into a synchronized stream for timed reproduction, meeting the remaining limitations of claim 1.
    • Motivation to Combine (for §103 grounds): To the extent any element is not explicitly disclosed, Petitioner argued it would have been obvious to a person of ordinary skill in the art (POSITA). For instance, if Little’s “channel capacity” and buffer size are considered inputs rather than actively “selected,” a POSITA would have found it obvious to make these parameters user-selectable to adapt the system for different network conditions.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in implementing such minor modifications, as they represented well-understood design choices in the field of multimedia streaming at the time.

Ground 2: Anticipation of Claim 5 over Azadegan - Claim 5 is anticipated by Azadegan.

  • Prior Art Relied Upon: Azadegan (Patent 5,819,004).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that claim 5, which recites a method for regenerating a replayable data stream, is fully anticipated by Azadegan. Azadegan teaches a system for re-encoding a video stream to adjust its quality. It discloses identifying “original level indicators” by storing the bit count of originally encoded frames in log files. A user then makes adjustments, generating a “current list of data elements” with new quantization values. Azadegan calculates a “current level indicator” (the new bit count for the modified frame) and compares it to the original to ensure the file size remains comparable. Finally, Azadegan teaches locating the original data portions in the stream and replacing them with the updated, re-encoded data portions, thus meeting all limitations for regenerating the stream as claimed.

Ground 3: Anticipation of Claims 6-7 over Joseph - Claims 6 and 7 are anticipated by Joseph.

  • Prior Art Relied Upon: Joseph (Patent 5,819,034).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Joseph, which describes an interactive television system, anticipates claims 6 and 7. Joseph’s server generates a reconfigurable data stream by combining video/audio data with executable code modules that can respond to user input at run-time. This stream contains a plurality of data portions (video, audio, code packets) with specified playback times controlled by time code data. The system receives conditional input statements by monitoring user input, which can vary the playback by generating new graphics or audio. Joseph’s packet multiplexer combines the auxiliary data portions (video/audio) and the conditional input statements (executable code) into a single data stream, anticipating the limitations of claim 6. Claim 7 is met because Joseph’s client device receives this stream at run-time, extracts the conditional statements (code modules), and applies them to effect a run-time variation in processing.

  • Additional Grounds: Petitioner asserted additional anticipation challenges against claims 8 and 12 based on Adams (Patent 5,541,662), which discloses a system for reproducing multimedia from a data stream containing interleaved data portions and associated commands.

4. Key Claim Construction Positions

  • "selecting a playback bandwidth" (claim 1): Petitioner proposed this term be construed as “specifying the transfer throughput of the distribution network and the available memory on the playback system within which data…are to be buffered.” This construction was central to the argument against Little, as it links the patent’s broad term “bandwidth” to the specific, disclosed concepts of channel capacity and buffer allocation in the prior art.
  • "receiving a conditional input statement appended to one or more of said data portions" (claim 6): Petitioner proposed this means incorporating the statement into the overall data stream, rather than physically attaching it to a specific data object. This construction was based on the patent’s specification and prosecution history and was crucial for arguing that Joseph’s system, which multiplexes code packets and media packets into a single stream, meets this limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1 and 4-12 of the ’091 patent as unpatentable.