PTAB

IPR2016-00754

Apple Inc v. Personalized Media Communications LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Signal Processing Apparatus and Methods
  • Brief Description: The ’635 patent discloses methods for controlling the operation of receivers and the decryption of encrypted data at a subscriber station. The claimed methods generally involve receiving encrypted digital programming that contains an encrypted digital control signal, decrypting that control signal, and then using the decrypted control signal to decrypt the main programming content for presentation to a user.

3. Grounds for Unpatentability

Ground 1: Invalidity over Guillou - Claims 1-3, 7, 21, and 29 are anticipated by Guillou; claims 4, 13, 18, 20, 28, 30, 32, and 33 are obvious over Guillou.

  • Prior Art Relied Upon: Guillou (Patent 4,337,483).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Guillou, which describes a teletext/viewdata video transmission system, discloses every element of numerous challenged claims. Guillou teaches a "double-key" encryption scheme where an encrypted access control message (Mᵢ) is transmitted with encrypted teletext data (Dⱼ). At the receiver, a first decryptor uses a subscriber key to decrypt the message Mᵢ and recover an operating key (K). This recovered key K, serving as the "decrypted control signal," is then used by a second decryptor to decrypt the teletext data Dⱼ, which serves as the "encrypted programming." Petitioner contended this two-step process directly maps to the methods recited in independent claims 1, 3, 13, and 21.
    • Motivation to Combine (for §103 grounds): For claims challenged as obvious over Guillou alone, Petitioner asserted that any minor differences would have been obvious modifications. For instance, Petitioner argued it would be obvious to apply Guillou's known teletext system, which includes text and graphics, to programming that constitutes "encrypted video" (claim 4) or to use the system in interactive contexts like Viewdata, which would suggest contacting a remote station (claim 30). Similarly, embedding well-known command and control instructions into the teletext data stream (claims 13, 18, 20) was presented as a predictable design choice.
    • Expectation of Success: A person of ordinary skill in the art (POSITA) would have had a high expectation of success in making these modifications, as they involved applying known techniques within their conventional uses to the established framework taught by Guillou.

Ground 2: Obviousness over Aminetzah and Bitzer - Claims 1, 2, 4, 7, 18, 20, and 33 are obvious over Aminetzah in view of Bitzer.

  • Prior Art Relied Upon: Aminetzah (Patent 4,388,643) and Bitzer (Patent 3,743,767).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Aminetzah discloses a pay-TV system that meets most claim limitations by teaching the scrambling of video programming and the transmission of an encrypted digital decryption key (DK) to a subscriber station. The station decrypts the DK and uses it to descramble the programming. However, Aminetzah focuses on scrambled analog video. Bitzer was introduced to supply the teaching of transmitting purely digital data and programming over standard television channels. The combination, Petitioner asserted, teaches a system for decrypting encrypted digital programming as required by the claims.
    • Motivation to Combine: A POSITA would combine Aminetzah's robust pay-TV security system with Bitzer’s method for digital data transmission for a clear and compelling reason: to expand the programming options available in the secure pay-TV system. This would allow a provider to offer secure digital services, such as teletext, educational programming, or other data services, over existing television broadcast infrastructure, thereby enhancing the value of the subscription service.
    • Expectation of Success: Both Aminetzah's security architecture and Bitzer's digital transmission methods were well-known technologies designed for television systems. Combining them to protect digital content would have been a straightforward integration of compatible technologies with predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 3, 21, and 28-30 based on Aminetzah alone, arguing its disclosure of a networked pay-TV system was sufficient to render these claims obvious without modification by another reference.

4. Key Claim Construction Positions

  • "decrypting"-related terms: Petitioner argued that under the broadest reasonable interpretation, "decrypting" should not be limited to digital data but should also encompass the "descrambling" of analog signals. This position was based on the ’635 patent's specification, which explicitly states that "decryptors ... may be conventional descramblers," and on prior PTAB decisions in related cases that adopted this broader construction. This construction was critical to applying prior art like Aminetzah that primarily discusses "scrambling."
  • "processor": Petitioner proposed the construction "a device that operates on data." This broad construction was advanced because the specification does not limit the term to a microprocessor but describes various hardwired logic circuits and decoders as processing information. This interpretation allows prior art disclosing such circuits to meet claim limitations reciting a "processor."
  • "unaccompanied by any non-digital information transmission": Petitioner argued this phrase should be construed to mean that the transmission is entirely digital, without any accompanying analog information. This construction is relevant for mapping to prior art like Bitzer, which describes "full-channel" digital transmissions that use the entire television channel bandwidth for digital data.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 7, 13, 18, 20-21, 28-30, and 32-33 of the ’635 patent as unpatentable.