PTAB

IPR2014-00557

Samsung Electronics Co Ltd v. Virginia Innovation Sciences Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Multimedia Communications With Different User Terminals
  • Brief Description: The ’398 patent relates to an apparatus and method for transporting multimedia content to a destination device. The system involves receiving content, determining the destination device’s communication protocols and signal formats, converting the content accordingly, and routing it to the device over a predetermined channel for display.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 58 and 63 over Karaoguz, Palin, and Seaman

  • Prior Art Relied Upon: Karaoguz (Patent 8,028,093), Palin (Patent 7,580,005), and Seaman (Application # 2004/0223614).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the combination of these three references disclosed every limitation of the challenged claims. The argument was built upon a previous Board decision (in IPR2013-00571) that had already instituted review on the parent claims (15, 55, and 62) of the ’398 patent based on Karaoguz and Palin.
      • Karaoguz was argued to teach the core system of the base claims: a media exchange network that adapts digital media parameters based on the capabilities of an end-user's viewing device. This system could receive a device profile (e.g., HDTV capability), adapt the media content to match, and push the adapted content to the destination device (e.g., a TV or set-top box) via established channels. Petitioner contended that Karaoguz disclosed all limitations of independent claim 15 and dependent claims 55 and 62.
      • Palin was introduced to address the "wireless terminal" or mobile device aspect of the claims. Palin disclosed a system for wirelessly transmitting an image from a mobile terminal (e.g., a cell phone) to an external display device (e.g., a television) to provide better display quality for the user. Petitioner argued this supplied the mobile context for the Karaoguz system.
      • Seaman was asserted to teach the specific limitations added by the challenged dependent claims 58 and 63. These claims require routing content to a television through an "HDMI television input" (claim 58) or a communication path that "implements an HDMI connection" (claim 63). Seaman disclosed a secure video receiver capable of delivering a video feed to a TV set's input. Critically, Seaman expressly listed HDMI as one of the possible standard video output formats for connecting to a TV.
    • Motivation to Combine: Petitioner presented a multi-step motivation for a person of ordinary skill in the art (POSITA).
      • First, a POSITA would combine the teachings of Karaoguz and Palin to integrate the convenience of a mobile, handheld terminal (from Palin) with the sophisticated media adaptation and distribution network of Karaoguz. This would allow users to manage and send content from a mobile device for viewing on a home television system.
      • Second, a POSITA would be motivated to further modify this combined system with the teachings of Seaman to take advantage of the HDTV capability explicitly disclosed in Karaoguz. Since Karaoguz taught adapting content for HDTVs, and Seaman taught that HDMI was a known, standard interface for connecting devices to HDTVs, it would have been an obvious and logical step to use an HDMI connection to realize the high-definition capabilities of the underlying system. The growing industry adoption of HDMI as the standard for high-definition signals provided a strong market-based motivation for this integration.
    • Expectation of Success: Petitioner argued that a POSITA would have had a high degree of success in making this combination. The integration involved applying known techniques (mobile device connectivity, HDMI video output) to a known type of system (media distribution network) to achieve the predictable result of high-quality video playback on a television. No undue experimentation would have been required, as each component was operating according to its known principles.

4. Key Claim Construction Positions

  • Petitioner stated that for the purposes of the IPR, claim terms should be given their broadest reasonable interpretation. It proposed adopting the constructions applied by the Board in the related IPR2013-00571 proceeding for key terms, asserting their relevance to the challenged claims:
    • "wireless terminal": a point in a system or communication network at which data can either enter or leave in a wireless manner.
    • "HDMI": high definition multimedia interface.
    • "wireless communication network": wireless network for transmitting voice or data.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 58 and 63 of the ’398 patent as unpatentable under 35 U.S.C. §103.