PTAB

IPR2014-01534

Amazon.com Inc v. Personalized Media Communications LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Processing Signals in a Network
  • Brief Description: The ’587 patent describes a method for processing signals within a network. The core technology involves an intermediate "transmitter station" that receives "incomplete processor instructions" from a remote source, generates new information locally based on a control signal, and inserts that information into the instructions to "complete" them before communicating the result to a final "receiver station."

3. Grounds for Unpatentability

Ground 1: Obviousness over Monat - Claim 9 is obvious over Monat.

  • Prior Art Relied Upon: Monat (Patent 4,556,904).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Monat, which discloses a teletext system, teaches every limitation of claim 9. In Monat, a "teletext encoding system" (the transmitter station) receives a teletext data stream from a remote "teletext page data source." Petitioner asserted this data stream constitutes "incomplete processor instructions" because it lacks certain control characters required for proper processing by a user's receiver. The system also receives "menu format data," which acts as a "control signal" to trigger the identification of user prompts within the data stream. Based on this, a "prompt identification code generator" creates new control codes (the generated information), which are then inserted into the data stream, thereby "completing" the instructions. The completed teletext information is then broadcast to the user's teletext receiver (the receiver station).
    • Motivation to Combine: Although this is a single-reference ground, Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to implement the functions disclosed in Monat using a general-purpose computer rather than specialized hardware. This motivation stemmed from the well-known flexibility, cost-effectiveness, and advantages of computer-based implementation for such data processing tasks.
    • Expectation of Success: Petitioner contended that since the underlying components and processing steps for teletext systems were well-understood at the time, a POSITA would have had a high expectation of success in implementing Monat's system on a computer.

Ground 2: Obviousness over Calo - Claim 9 is obvious over Calo.

  • Prior Art Relied Upon: Calo (Patent 4,805,134).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Calo’s Videotex Application Network (“VAN”) discloses the claimed method. In Calo, an "Operations Node" (ON), acting as the transmitter station, can receive an information transmission, such as a videotex page, from a remote, distributed node. Petitioner asserted this page represents "incomplete processor instructions" because Calo explicitly describes that pages may require "additional dynamic processing to complete the page retrieved." This completion process is triggered by a "control signal," which Petitioner identified as either data embedded within the page itself indicating a need for completion or a separate "remote start request" signal. In response, the ON's host computer executes a program that "merges the retrieved page with data that the program has derived from other sources" (Value-Added Page Creation), thereby generating information to complete the page. The completed page is then communicated to an end-user terminal (the receiver station).
    • Motivation to Combine: Petitioner contended that Calo teaches all the elements of the claimed method in the context of a dynamic, interactive videotex system. A POSITA would have been motivated to combine these teachings in the manner claimed to provide enhanced, customized content to users, which was a specific goal of Calo's "Value-Added Page Creation" service.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a high expectation of success because Calo's system was designed to operate using well-known components and industry-standard protocols like the North American Presentation Level Protocol Syntax (NAPLPS), making the claimed sequence of operations predictable and achievable.

4. Key Claim Construction Positions

  • "Incomplete Processor Instructions": Petitioner argued for a broad construction of this term to mean "processor instructions to which information will be added prior to the processor instructions being transmitted to a particular receiver station." This construction was based on the specification's disclosure that adding even a few "padding bits" to a command is sufficient to "complete" it. This interpretation was critical for arguing that the teletext data in Monat and the dynamically-generated videotex pages in Calo met this claim limitation.
  • "Control Signal": Petitioner proposed that this term should be construed as "an electrical quantity that is operative to cause a responsive action in a device," citing a prior PTAB construction for a related patent. This broad definition allowed Petitioner to identify various signals and data within the prior art references—such as Monat's "menu format data" or Calo's "remote start request"—as satisfying this limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claim 9 of the ’587 patent as unpatentable.