PTAB

IPR2015-02007

DirecTV LLC v. Qurio Holdings Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cross-Layer Offload Engine for Network Gateway
  • Brief Description: The ’567 patent describes a network gateway that interconnects a high-speed Wide Area Network (WAN) and a lower-speed Wireless Local Area Network (WLAN). The gateway features an adaptable cross-layer offload engine to manage bandwidth by caching incoming WAN data, performing rule-based inspections (including for DRM), moving data from non-secure to secure caches, and transmitting it to user devices on the WLAN.

3. Grounds for Unpatentability

Ground 1: Obviousness over Taesombut, Ducharme, Wijting, and O'Connor - Claims 1, 3, 6, 10-15, 20-21, and 26-34 are obvious over Taesombut in view of Ducharme, Wijting, and O'Connor.

  • Prior Art Relied Upon: Taesombut (a 2003 conference paper), Ducharme (WO 2003/094510), Wijting (a 2004 journal article), and O'Connor (Patent 7,412,579).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references taught every element of the challenged claims. Taesombut was asserted to disclose the base gateway connecting a WAN to a WLAN for delivering media with DRM restrictions and format conversion. Wijting taught using a cross-layer "performance enhancing proxy" (PEP) with traffic classifiers and schedulers to optimize performance over wireless links, allegedly disclosing the claimed "adaptable cross-layer offload engine." Ducharme provided more detailed teachings on implementing rights-based rules (e.g., Entitlement Management Messages) and transcoding video streams. Finally, O'Connor disclosed a system-on-chip architecture for network devices that partitioned memory into secure and non-secure sections, corresponding to the claimed caching scheme.
    • Motivation to Combine: A POSITA would combine these references to improve the known gateway art. Petitioner argued a POSITA would be motivated to apply Wijting's cross-layer optimization techniques to the gateways of Taesombut and Ducharme to improve the performance of video delivery over a wireless link. Ducharme’s more detailed DRM and transcoding methods would be seen as a natural implementation choice for the system in Taesombut. Finally, to secure the content decrypted for processing within the gateway (as taught by Taesombut and Ducharme), a POSITA would incorporate O'Connor's secure memory partitioning to prevent unauthorized copying.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying known techniques (cross-layer optimization, secure memory) to solve predictable problems (poor wireless performance, content security) in existing gateway systems.

Ground 2: Obviousness over DPR2325, CableHome 1.1, Srivastava, Safadi, and O'Connor - Claims 1, 3, 6, 10-15, 20-21, and 26-34 are obvious over DPR2325, CableHome 1.1, Srivastava, Safadi, and O'Connor.

  • Prior Art Relied Upon: DPR2325 (a 2005 cable modem user's guide), CableHome 1.1 (a 2004 industry specification), Srivastava (a 2005 IEEE article), Safadi (Application # 2003/0126086), and O'Connor (Patent 7,412,579).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that a commercial, standards-compliant gateway already embodied the core invention, which could be readily modified with other known technologies. The DPR2325 manual described a commercial gateway compliant with the CableHome 1.1 specification, which together disclosed a residential gateway connecting a cable WAN to a home WLAN and implementing cross-layer Quality of Service (QoS) features. Srivastava provided a survey of the well-known principles of cross-layer design that motivated the QoS features in CableHome 1.1. Safadi taught a network device that performs DRM scheme conversion and content transcoding to ensure compatibility with various user devices on a LAN. O'Connor, as in Ground 1, taught the use of secure and non-secure memory partitions.
    • Motivation to Combine: A POSITA would be motivated to enhance the standard-compliant DPR2325/CableHome 1.1 gateway to improve its functionality. The CableHome 1.1 specification itself identified goals like supporting next-generation services and enhanced security (e.g., copy protection). To meet these goals and support the wide variety of devices connectable to the DPR2325 gateway, a POSITA would integrate Safadi's DRM and transcoding capabilities. The known benefits of cross-layer design, as surveyed by Srivastava, would further motivate optimizing the gateway’s wireless performance. To implement these transcoding and DRM functions securely, a POSITA would use O'Connor's memory partitioning scheme to protect decrypted content from unauthorized access.
    • Expectation of Success: The combination was portrayed as a predictable integration of known solutions. A POSITA would expect success in adding transcoding (Safadi) and secure memory (O'Connor) to a commercial gateway (DPR2325) to achieve the stated industry goals of compatibility and security.

4. Key Claim Construction Positions

  • Petitioner argued that several key claim terms should be construed as means-plus-function limitations under 35 U.S.C. § 112, ¶ 6, pursuant to the Federal Circuit's decision in Williamson v. Citrix Online, LLC.
  • Terms identified included "offload engine," "rule check engine," and "DRM function."
  • For example, Petitioner proposed that the term "offload engine" (Claim 1) lacks a sufficiently definite structural meaning and should be construed by its functions: receiving content from the WAN, storing it in a non-secure cache to support the WAN's data rate, and transmitting it to devices on the WLAN at a second data rate.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 3, 6, 10-15, 20-21, and 26-34 of the ’567 patent as unpatentable.