PTAB

IPR2016-00753

Apple Inc v. Personalized Media Communications LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Signal processing apparatus and methods
  • Brief Description: The ’649 patent discloses methods for processing broadcast signals at a receiver station. The system uses embedded digital information within a transmission to control how a receiver with multiple processors processes and presents television or video signals to a user.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mustafa in view of Iijima - Claims 39, 54, 62, and 67 are obvious over Mustafa in view of Iijima.

  • Prior Art Relied Upon: Mustafa (Patent 4,789,895) and Iijima (Patent 4,215,369).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mustafa taught a television system where user terminals receive and process transmissions containing video frames, digitally encoded audio, and control information. The transmission frame data was divided into two parts: auxiliary information (e.g., terminal address, mode code) and active content (video/audio). Petitioner mapped the auxiliary information to the claimed "message stream" and the active content to the "digital television signals." Mustafa’s receiver detected the mode code from the message stream, compared it to stored values, and then inputted the active content to separate audio or video processors based on the result of the comparison, thus disclosing the core limitations of the challenged claims. For claim 67, Petitioner contended that Mustafa’s mode code, which identifies a frame as video or audio and distinguishes message streams, constituted the claimed "cadence information."
    • Motivation to Combine: The petition asserted this combination as an alternative ground, applicable if the claims were construed to require a fully digital transmission rather than Mustafa's analog NTSC format with embedded digital data. Iijima taught a well-known digital transmission system for converting standard analog NTSC video into a digitized stream for transmission and then converting it back at a receiver. A POSITA would combine Mustafa with Iijima to gain the known benefits of fully digital transmission, such as improved signal quality and superior noise immunity.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved replacing the analog signal paths in Mustafa’s architecture with the conventional and compatible digital transmission system taught by Iijima, a straightforward substitution that would yield predictable results.

Ground 2: Obviousness over Campbell in view of Widergren - Claims 39, 54, 62, and 67 are obvious over Campbell in view of Widergren.

  • Prior Art Relied Upon: Campbell (Patent 4,536,791) and Widergren (Patent 4,302,775).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Campbell disclosed a cable television system that controls access to programming using digital data transmitted in the vertical blanking interval (VBI) of the television signal. This VBI data, which included subscriber authorization and program tier codes, constituted the claimed "message stream" and "control information." Campbell’s receiver (a converter) extracted this control information and compared it against stored subscriber data ("stored function invoking data"). Based on a match, the system enabled processors like a video descrambler and an audio level/mute control unit to process the incoming signal. Petitioner argued that the various identifiers in Campbell’s VBI data served as the claimed "cadence information" by allowing the receiver to distinguish between different messages.
    • Motivation to Combine: This ground was also presented as an alternative argument if the claims were construed to require a fully digital signal. A POSITA would combine Campbell’s access-control system with the digital transmission techniques of Widergren. Widergren disclosed a system for converting analog NTSC signals into a compressed digital data stream for transmission. A POSITA would have been motivated to implement such a system to achieve the benefits of an all-digital architecture, including increased capacity and the ability to use more robust digital scrambling methods than were possible in Campbell's analog system.
    • Expectation of Success: A POSITA would have expected success in combining the references, as it involved applying a known digital conversion and transmission technique (Widergren) to an existing cable TV system (Campbell) to predictably improve its performance and security.

  • Additional Grounds: Petitioner asserted that claims 39, 54, 62, and 67 were also independently obvious over Mustafa alone and over Campbell in view of the knowledge of a POSITA. The arguments relied on the same core teachings of Mustafa and Campbell detailed above, with the contention that certain claim elements were either inherently disclosed or would have been obvious modifications.

4. Key Claim Construction Positions

Petitioner proposed constructions for several key terms for purposes of the IPR, arguing they were central to the invalidity analysis.

  • "digital television signals" / "digital video signals": Petitioner argued the broadest reasonable interpretation is "signals entirely or partially encoded in a digital format." This construction was based on the specification and extensive prosecution history, where the applicant clarified that the term was intended to cover transmissions comprising both analog and digital components, not just purely digital signals. This interpretation supports the single-reference obviousness grounds.
  • "cadence information": Proposed as "information used to distinguish the individual messages of a message stream." Petitioner argued this term was not one of art, and its meaning was derived from the specification’s description of using headers, tokens, and other identifiers to enable a receiver to parse a data stream.
  • "processor": Proposed as "a device that operates on data." This broad construction was based on the term's plain meaning and its varied use in the specification to describe components ranging from decoders and comparators to more complex microprocessors.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 39, 54, 62, and 67 of the ’649 patent as unpatentable under 35 U.S.C. §103.