PTAB

IPR2014-01530

Amazon.com Inc v. Personalized Media Communications LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Signal Processing and Communications System
  • Brief Description: The ’956 patent describes a method for signal processing within a network. The method involves a transmitter station sending "generally applicable information" to multiple receiver stations, which then output recommendations for "subscriber-specific action."

3. Grounds for Unpatentability

Ground 1: Obviousness over Higgins and Metcalfe - Claim 6 is obvious over Higgins in view of Metcalfe.

  • Prior Art Relied Upon: Higgins (Patent 5,270,922) and Metcalfe (a 1976 publication titled Ethernet: Distributed Packet Switching for Local Computer Networks).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Higgins disclosed all elements of claim 6 except for the specific structure of a "module." Higgins described a networked financial information system where a central ticker plant broadcasts stock trade data ("generally applicable information") to branch computers ("transmitter stations"). These branch computers then forward the data to individual broker workstations ("receiver stations"). Each workstation, based on pre-set, user-specific price limits, generates alerts ("recommending subscriber specific action") advising a broker to consider buying or selling a stock. Petitioner asserted that Metcalfe, which described the widely-known Ethernet protocol, supplied the missing "module" element. An Ethernet data packet, as taught by Metcalfe, would be the obvious data structure (the "module") for transmitting the stock information from the branch computers to the workstations over the local network connections inherent in the Higgins system.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Higgins with Metcalfe because, at the time of the invention, Ethernet was a well-known, simple, inexpensive, and widely available networking technology. Using standard Ethernet packets to transmit data between computers in the Higgins network represented a routine and logical implementation choice, achievable with off-the-shelf components.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination. Implementing a local network using the standard Ethernet protocol described in Metcalfe to connect the various computers in the Higgins system was a straightforward application of a conventional technology for its intended purpose.

Ground 2: Obviousness over Furukawa - Claim 6 is obvious over Furukawa.

  • Prior Art Relied Upon: Furukawa (Patent 4,439,784).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Furukawa, by itself, rendered claim 6 obvious. Furukawa disclosed a two-way CATV system, for example in a hotel, where a central facility ("transmitter station") communicates with multiple terminal units in guest rooms ("receiver stations"). The system could transmit "spot messages" to televisions. These messages could be general information (a fire alarm) or subscriber-specific, such as a message to a specific tour group reminding them of their departure time and requesting acknowledgement ("recommending subscriber specific action"). The down-data signal containing the spot-channel instruction and the addresses of the targeted terminal units constituted the claimed "module." The system also allowed guests to respond to messages (e.g., by pressing an acknowledgement button), thereby establishing communication with a remote computer room ("remote station"). Petitioner argued this single reference taught every element of the challenged claim.
    • Motivation to Combine: This ground was based on a single reference, asserting that Furukawa alone disclosed all the claimed features. The motivation was inherent in the system's design, which used a network to transmit both general and specific information to end-users and provided a mechanism for recommending and confirming actions.
    • Expectation of Success: As Furukawa described a complete, functional system, a POSITA would have understood its teachings to be operable and would have had a clear expectation that the disclosed methods would work as described.

4. Key Claim Construction Positions

  • "Module": Petitioner argued that while the term is likely indefinite, under the broadest reasonable interpretation standard, it must encompass "any unit of digital data." This construction was based on examples in the ’956 patent’s specification where "modules" were used to store disparate data types like street addresses, audio recordings, and video images, without a specified format. This broad interpretation was critical for mapping prior art data structures, like an Ethernet packet (Metcalfe) or a down-data signal (Furukawa), to the claim.
  • "Recommending ... Action": Petitioner asserted that this claim limitation referred to non-functional descriptive material that should be afforded no patentable weight. The argument was that the technical process of outputting information (e.g., video on a screen) is the same regardless of whether the content is a newscast or a recommendation. Petitioner argued that the claim failed to specify any functional relationship between the recommendation and the rest of the method, making it an unpatentable attempt to claim the informational content itself.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claim 6 of Patent 7,864,956 as unpatentable under 35 U.S.C. §103.