PTAB

IPR2015-00845

Lenovo United States Inc v. Personal Audio LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Audio Program Player Including a Dynamic Program Selection Controller
  • Brief Description: The ’076 patent describes an audio player device that reproduces a sequence of audio program segments. The playback order is established by a separate "sequencing file," and the device is configured to accept user commands to skip forward or backward within that established sequence.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chase in view of Loeb - Claims 1 and 4-6 are obvious over Chase in view of Loeb.

  • Prior Art Relied Upon: Chase (Application # 2002/0177914) and Loeb (a 1992 article titled "Architecting Personalized Delivery of Multimedia Information").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chase taught the core system of an "affiliate terminal" (a player) that receives and stores audio files along with a "play list" (a file of data establishing a sequence) that dictates the playback order. Chase’s system continuously reproduces the audio segments in the prescribed order and includes a remote control with keys for navigating the playlist, including starting the next segment.
    • Motivation to Combine: Petitioner contended that while Chase’s system was geared toward a professional user like a radio DJ, Loeb taught a "personalized music system" with a simple, high-level user interface designed for a general listener. A person of ordinary skill in the art (POSITA) would combine Chase's playlist-based playback architecture with Loeb's user-friendly interface to create a more commercially appealing product that allows for personalized selection and simple control of a media playlist.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as it involved applying known user interface design principles (from Loeb) to a known media playback system (from Chase) using common programming techniques, yielding a predictable result.

Ground 2: Obviousness over Chase in view of Loeb and Inazawa - Claims 2-3 and 14-15 are obvious over Chase in view of Loeb and further in view of Inazawa.

  • Prior Art Relied Upon: Chase (Application # 2002/0177914), Loeb (1992 article), and Inazawa (Patent 4,811,315).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Chase/Loeb combination from Ground 1, which Petitioner argued established the basic player system with skip-forward capability. Inazawa was introduced to teach the specific "skip backward" functionalities recited in claims 2 and 3. Inazawa disclosed a disc player with a control key that performs different functions based on timing: a press after a certain playback duration restarts the current track ("a single one of said second commands"), while two consecutive presses within a time period skips to the beginning of the preceding track ("two consecutive ones of said second commands"). This functionality directly maps to the limitations of claims 2 and 3.
    • Motivation to Combine: A POSITA would be motivated to add the sophisticated skip-backward functionality from Inazawa to the Chase/Loeb combination to provide a more complete and intuitive set of user navigation controls. Improving a user interface with well-understood features like those in Inazawa would have been a simple and logical design modification to enhance the product's usability.
    • Expectation of Success: Petitioner asserted that implementing the time-based command logic of Inazawa within the software framework of the Chase/Loeb system was a mere design choice between hardware and software implementations. A POSITA could predictably implement this known functionality using common programming techniques.

4. Key Claim Construction Positions

Petitioner relied heavily on claim constructions adopted during a prior litigation involving the ’076 patent (Personal Audio, LLC v. Apple, Inc.), particularly for the numerous means-plus-function limitations.

  • "means for detecting a first command indicative of a request to skip forward" (claim 1): Petitioner argued this term's function is detecting a skip-forward command. The corresponding structure was identified as a general-purpose computer programmed to perform a specific algorithm, including using an "if-then-else" construct to determine if user input is a command and a "branch" construct to select the "Skip" command for execution.
  • "means responsive to said first command..." (claim 1): The function of this term is to discontinue the current track and begin playing the next track in the sequence in response to the skip command. The corresponding structure was identified as a general-purpose computer programmed to perform an algorithm that scans forward in the sequencing file to locate the next record, resets a "CurrentPlay" variable, and then fetches and plays the program segment identified in that new record.
  • "means responsive to... two consecutive ones of said second commands..." (claim 3): The function is to skip to the preceding track upon detection of two consecutive "back" commands. Petitioner argued the structure is a general-purpose computer programmed to perform an algorithm that, in response to a second "back" command within a predetermined time, scans backward in the sequencing file to locate the previous record and initiates playback from there.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-6 and 14-15 of the ’076 patent as unpatentable.