PTAB

IPR2016-00971

Apple Inc v. OpenTV Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Restricting or Controlling Access Rights of Interactive Television Applications and Carousels
  • Brief Description: The ’081 patent describes a method and system for an interactive television environment that uses an electronic "credential" to control the access rights, privileges, and restrictions of applications. The credential contains information identifying an application and its authorized functions.

3. Grounds for Unpatentability

Ground 1: Anticipation by Rohatgi - Claims 1-3, 23, and 24 are anticipated by Rohatgi under 35 U.S.C. §102.

  • Prior Art Relied Upon: Rohatgi (European Patent Application No. EP 0752786).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rohatgi, which describes authenticating applications in an interactive information system, disclosed every limitation of the challenged claims. Rohatgi taught an interactive application containing a "Directory Module" which, in turn, includes a "certificate" and "authorization flags." Petitioner contended this "Directory Module" constitutes the claimed "credential" as it contains information identifying the application (e.g., "Application ID") and its permissions (e.g., "authorization flags" that grant or deny access to privileged actions like establishing a remote connection). Rohatgi’s system verified this credential by decoding and checking the certificate for authenticity before executing the application, thus meeting the "verifying" limitation of independent claims 1 and 23.
    • Dependent Claims Mapping: For dependent claim 2, Petitioner asserted Rohatgi met the limitation of storing information if the credential is valid, as Rohatgi's system deletes modules that cannot be verified. For dependent claim 3, Rohatgi’s certificate explicitly included an "expiration date," and the verification process involved comparing this against the current time and date. For dependent claim 24, Rohatgi disclosed that its control unit could be a "PC-data processor" or a "personal computer," which meets the "general-purpose computer" limitation.

Ground 2: Obviousness over Apperson and Metz - Claims 1-3, 23, and 24 are obvious over Apperson in view of Metz under 35 U.S.C. §103.

  • Prior Art Relied Upon: Apperson (Patent 5,978,484) and Metz (Patent 5,768,539).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Apperson taught a general method for securely distributing and executing software objects using a credential-like structure, while Metz provided the specific context of an interactive television system. Apperson disclosed loading an application with an associated "privilege request code," "digital signature," and "digital credentials," which collectively serve as the claimed "credential" to identify the application and its authorized functions (e.g., file I/O, network operations). A client computer verifies this credential and monitors the application during execution to prevent unauthorized actions. Metz disclosed an interactive television system that downloads applications but provided only a high-level description of validating them before execution. The combination of Apperson’s detailed security method with Metz’s interactive television environment rendered the claimed invention obvious.
    • Motivation to Combine: A POSITA would combine Apperson and Metz to improve the security and functionality of the interactive television system described in Metz. Metz identified the need to validate downloaded applications but did not specify a detailed mechanism. Apperson provided a well-defined method for validating applications and controlling their execution permissions using a credential structure. A POSITA would have been motivated to implement the known security techniques from Apperson into the known interactive television system of Metz to achieve the predictable result of a secure application environment.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination, as it involved applying a known security technique (from Apperson) to a known type of system (Metz's interactive television system) where such security was desirable.

4. Key Claim Construction Positions

  • "Credential" (claims 1-3 and 23): Petitioner proposed that the broadest reasonable construction of "credential" is "information that identifies an object and its privileges, rights, and restrictions."
  • This construction was central to Petitioner's arguments, as it allowed data structures described in the prior art, such as Rohatgi’s "Directory Module" or the combination of Apperson’s "privilege request code" and "digital signature," to be considered a "credential" under the claims, even if not explicitly named as such in the references. This interpretation is supported by the ’081 patent's specification, which describes a credential as a collection of information serving these two purposes.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-3, 23, and 24 of Patent 6,148,081 as unpatentable based on the two grounds presented.