PTAB

IPR2015-00971

Apple Inc v. Nagravision SA

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Sharing Encrypted Products
  • Brief Description: The ’586 patent discloses a system for sharing encrypted digital products (e.g., video-on-demand) among multiple user units. The system is managed by a central operating center that distributes both the encrypted product and the necessary decryption authorizations, aiming to reduce bandwidth demands on the central server by allowing local sharing between user units.

3. Grounds for Unpatentability

Ground 1: Anticipation over Arnold - Claims 1 and 2 are anticipated by Arnold under 35 U.S.C. §102.

  • Prior Art Relied Upon: Arnold (Application # 2010/0175093), which claims priority to a provisional application filed in March 2000, prior to the ’586 patent’s priority date.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Arnold discloses every element of the challenged claims. Arnold’s system includes a central "service center" and "content server" that function as the claimed "operating centre" by providing a large number of products (e.g., program guides, media content) to a plurality of DVRs, which function as the claimed "user units." These DVRs are taught to include both storage means (a hard disk or "content database") and security means (a "local decryption facility based on a smart-card"). Arnold explicitly discloses connecting these DVRs over a local, bi-directional network (e.g., a home LAN) for transferring media streams between units.
    • Prior Art Mapping (Encryption): Arnold further teaches transferring encrypted content between a first DVR and a second DVR. The content is encrypted with a "recording key," which Petitioner asserted corresponds to the claimed "transport key." The operating center (content server) transmits the necessary authorizations—the recording key and a "strong key," both encrypted with the user unit’s public key—to the DVR to enable decryption. This directly maps to the claim limitations requiring the operating center to transmit an authorization to the second unit to decrypt the product, and for the second unit to possess decryption means for a transport key encrypted with a key specific to it.

Ground 2: Obviousness over Acharya Combinations - Claims 1 and 2 are obvious over Acharya alone or in view of Yeager or Schneier under 35 U.S.C. §103.

  • Prior Art Relied Upon: Acharya (a 1999 Ph.D. dissertation), Yeager (a 1996 book on web server technology), and Schneier (a 1996 book on applied cryptography).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Acharya’s "MiddleMan" system discloses the core, non-security-related claim limitations. Acharya teaches a system with a central web server (the "operating centre") that distributes video content to multiple "user machines" on a local network. To solve the "server bottleneck" problem, these user machines cache content in local storage and share it directly over bi-directional links, thus disclosing the claimed architecture of local product sharing. Acharya explicitly noted the need to add an "authentication scheme" and to "encrypt cache contents to prevent unauthorized access."
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to combine Acharya with the well-known, standard security solutions taught by Yeager or Schneier. All three references address the common field of secure content distribution over networks. Acharya expressly identified the problem of securing cached content and invited the implementation of security measures. Yeager and Schneier provided the solution by teaching the exact type of hybrid cryptographic scheme recited in the ’586 patent: using a symmetric session key (the "transport key") to encrypt content and a user-specific public key to encrypt and securely distribute the session key.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying the standard, widely-used cryptographic methods from Yeager and Schneier to the content distribution system of Acharya. This combination involved applying known techniques to a known system to achieve a predictable and desired result—secure local content sharing.

4. Key Claim Construction Positions

Petitioner proposed constructions for several key terms, arguing they were critical to the invalidity analysis.

  • "operating centre": Construed as "a central network node such as a server that has products for distribution to a plurality of user units." This construction was based on the specification and prosecution history, where the applicant equated the term with a video server.
  • "security means": Construed as "a module that stores cryptographic keys and processes encrypted products." This was derived from the specification’s disclosure of a "security module" and amendments made during prosecution.
  • "transport key": Construed as "a key used to encrypt a product."
  • "the authorization": Construed as "a key or right necessary for the decryption of a product."
  • Means-Plus-Function Terms: Petitioner argued that several "means for" limitations should be construed under §112, ¶6. For example, "means for transferring a product" was construed as performing the function of transferring the product with the corresponding structure of "an interface to a bi-directional communication link in a local network."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1 and 2 of Patent 6,985,586 as unpatentable.