PTAB

IPR2014-01272

Cisco Systems Inc v. Custom Media Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Method and System for Customizing and Distributing Presentations for User Sites
  • Brief Description: The ’275 patent describes a system for distributing customized media presentations while reducing network bandwidth. A server broadcasts a single, universal presentation media object containing multiple media components to a group of user devices, which then locally select and arrange components to create a customized presentation based on locally stored user profile data and presentation logic objects.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1 and 13 by Seidman

  • Prior Art Relied Upon: Seidman (Patent 6,298,482).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seidman disclosed every limitation of independent claims 1 and 13. Seidman described a system where a head end broadcasts a multiplexed video stream (a "single universal presentation media object" with "media components") to multiple set-top boxes (STBs). The STBs gathered user viewing statistics ("gathering user profile information") to create a locally stored "viewer profile" ("profile data object"). The head end created "control information" based on viewer profiles and sent it to the STBs; this control information functioned as the claimed "presentation logic object." Each STB then used its local viewer profile and the control information to select and arrange specific program segments from the broadcasted stream to create a customized presentation for the user. Petitioner asserted that Seidman’s "control information" was equivalent to the ’275 patent’s "presentation logic objects" as it was created based on viewer profiles to facilitate customized presentations.

Ground 2: Anticipation of Claims 1 and 13 by Rosser

  • Prior Art Relied Upon: Rosser (Patent 6,446,261).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Rosser also taught all elements of claims 1 and 13. Rosser disclosed a system for targeting advertisements where a central system broadcasts a sequence of ads ("single universal presentation media object") to multiple STBs. The STBs monitored viewing habits to create a local "viewer profile" ("profile data object"). The central system created "viewer profile keys" ("presentation logic objects") configured to link specific ads with specific viewer profiles. Each STB used its local viewer profile and the viewer profile keys to compare profiles and select ("selecting") and insert ("arranging") specific ads into the video signal, thereby creating a customized presentation. The viewer profile keys were created based on viewer profiles and sent to the STBs to facilitate the customization logic.

Ground 3: Obviousness of Claims 1 and 13 over a Combination of Seidman, Rosser, and/or Park

  • Prior Art Relied Upon: Seidman (Patent 6,298,482), Rosser (Patent 6,446,261), and Park (WO 97/17771).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that to the extent any single reference did not disclose a particular limitation, the combination of Seidman, Rosser, and/or Park rendered the claims obvious. For example, Seidman’s teaching of creating control information based on user selections could be applied to Rosser’s system of viewer profile keys or Park’s system of target profiles. Similarly, Rosser’s disclosure of storing logic objects (viewer profile keys) locally could be applied to Seidman’s system to explicitly store the control information in the STB’s RAM, which Petitioner argued was an obvious design choice.
    • Motivation to Combine: A POSITA would combine the teachings because all three references operated in the same field of endeavor—customizing media content for specific users—and proposed solutions to common problems. The motivation included improving the customization of media presentations (e.g., targeted advertising), enhancing computational efficiency, and managing bandwidth, all of which were predictable outcomes of combining known elements from the prior art.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these systems, as they employed well-known principles of client-server architecture, profile-based filtering, and broadcast media delivery to achieve predictable results.

  • Additional Grounds: Petitioner asserted numerous additional grounds, including that Seidman, Rosser, and Park each individually rendered the claims obvious. Further grounds for dependent claims 2-24 were asserted based on combinations of Seidman, Rosser, Park, Hendricks (Patent 6,738,978), Ellis (Patent 7,185,355), and Ellis II (Patent 5,760,821), arguing that adding features like periodic updates or using default profiles were obvious modifications.

4. Key Claim Construction Positions

Petitioner dedicated a substantial portion of the petition to arguing for broad constructions of key claim terms, contending these constructions were necessary for the claims to be enabled and definite, and that under these constructions, the claims were anticipated or obvious.

  • "presentation logic objects": Petitioner argued this term should be construed broadly as simply "collections of logic or data that can facilitate the creation of customized media presentations." This construction was broad enough to encompass the "control information" of Seidman and the "viewer profile keys" of Rosser, which provided rules for customization but were not necessarily complex software objects.
  • "a single universal presentation media object": Petitioner proposed this term be construed as "a common presentation media object that is broadcasted to each user computer means... and includes a set of media components that can be used... to locally create a customized presentation." This construction emphasized the "common broadcast" aspect, aligning it with the broadcast streams disclosed in Seidman, Rosser, and Park.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-24 of the ’275 patent as unpatentable under 35 U.S.C. §102 and §103.