PTAB

IPR2014-01181

Samsung Electronics Co Ltd v. Affinity Labs Of Texas LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Managing Media
  • Brief Description: The ’641 patent discloses a system for delivering media content to a wireless telephone, which then communicates information about the available content to a separate recipient device (e.g., a car audio system). The recipient device generates a graphical menu for selection, and upon user selection, the telephone streams the audio to the recipient device over a local asynchronous wireless network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ito, Haartsen, Nokia, and Rydbeck - Claims 1-3, 5, 8-11, 13, and 14 are obvious over Ito in view of Haartsen, Nokia, and Rydbeck.

  • Prior Art Relied Upon: Ito (Patent 6,990,334), Haartsen (Patent 6,973,067), Nokia (Nokia 9000/9000i Owner’s Manual), and Rydbeck (Patent 7,123,936).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ito, the primary reference, disclosed the core invention: a wireless phone that receives music data and streams it to a second device (e.g., a vehicle audio system), including sending corresponding menu information for display and selection on the second device. To meet remaining limitations, Petitioner mapped Haartsen’s teachings of multi-media communication systems to provide the claimed asynchronous channel and specified that Haartsen explicitly taught its system could be implemented in Bluetooth. Petitioner then mapped the Nokia manual, which disclosed a commercially available phone with conventional features, to meet limitations such as a rechargeable battery, a physical interface for data and charging, email/voicemail clients, an internet browser, and hands-free capability. Finally, to meet the limitation of altering audio output upon receipt of a call, Petitioner mapped Rydbeck, which taught automatically muting or stopping audio playback when an incoming call is received.
    • Motivation to Combine: A POSITA would combine these references to improve upon Ito’s base system. Haartsen would be used to implement the local wireless connection with the known, cost-effective Bluetooth standard, which was being widely adopted. Nokia would be consulted to incorporate commonplace features expected in a commercial wireless phone to enhance its functionality and user convenience. Rydbeck would be added to provide the beneficial and logical feature of prioritizing a phone call over music playback, improving the user experience.
    • Expectation of Success: Petitioner contended that combining these known elements for their intended purposes would have been a routine and predictable integration of existing technologies. A POSITA would have had a clear expectation of success, as it involved implementing known hardware and software features to add well-understood, predictable functionality to a base system.

Ground 2: Obviousness over Lee, Nokia, Lau, and Haartsen - Claims 1-3, 5, 9, 10, 13, and 14 are obvious over Lee in view of Nokia, Lau, and Haartsen.

  • Prior Art Relied Upon: Lee (Patent 6,728,531), Nokia (Nokia 9000/9000i Owner’s Manual), Lau (Patent 6,772,212), and Haartsen (Patent 6,973,067).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Lee as an alternative primary reference that disclosed a cellular phone receiving audio broadcasts (e.g., internet radio) via a wide-area network and wirelessly communicating with a multimedia device in a vehicle using a local network like Bluetooth. Petitioner argued that Lau complemented Lee by teaching a dedicated audio/visual server system where a server sends menu information to a vehicle's head unit for display, allowing the user to select tracks for playback. As in the first ground, Haartsen was cited to provide the explicit teaching of an asynchronous data transfer protocol over the local Bluetooth network. Nokia was again cited for disclosing a host of conventional and commercially necessary phone features missing from Lee, such as a rechargeable battery, a physical data/power interface, and applications for email, internet, and wireless software upgrades.
    • Motivation to Combine: A POSITA would combine Lee’s wireless phone system with Lau’s teachings to provide a more robust and user-friendly method for menu generation and audio streaming to a vehicle head unit. Haartsen would be incorporated to ensure the local Bluetooth communication was asynchronous, a conventional method for conserving bandwidth. Nokia’s features would be added to Lee’s phone for the same reasons as in the Ito combination: to create a commercially viable product with expected functionalities.
    • Expectation of Success: Petitioner argued that combining these prior art elements involved applying known solutions to achieve predictable results. A POSITA would have had a high expectation of success in creating the claimed system from these well-understood components.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges based on various other combinations of the primary references (Ito, Lee) with the secondary references (Haartsen, Nokia, Rydbeck, Lau, Galensky). These grounds relied on similar motivations to combine to add known features like variable-rate streaming (from Galensky) or to substitute components from one system into another.

4. Key Claim Construction Positions

  • "stream" / "streaming audio signal": For the purposes of the inter partes review (IPR), Petitioner proposed construing these terms to mean "transfer as a flow of data" and "audio signal transferred as a flow of data," respectively. This construction, based on the specification and prosecution history, avoids limiting the claim to a specific, real-time-only protocol.
  • "[wireless] communication rate": Petitioner construed this term to mean "speed at which data is [wirelessly] transmitted." This construction reflects the plain and ordinary meaning of the words.
  • "CD quality listening experience": Petitioner proposed this term be construed as "a listening experience that is similar to that of a CD." This construction is based on language in the specification and avoids a narrow, technical definition tied to the Red Book audio CD standard.

5. Relief Requested

  • Petitioner requested the institution of an IPR and the cancellation of claims 1-3 and 5-14 of the ’641 patent as unpatentable under 35 U.S.C. §103.