PTAB

IPR2016-01161

WebPower Inc v. WAG Acquisition LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Streaming Media Buffering System
  • Brief Description: The ’011 patent discloses methods and systems for streaming media over the Internet. The invention aims to provide uninterrupted playback by transmitting media data from a server to a client’s buffer at a rate faster than the playback rate, particularly when the buffer is not full, to ensure it remains replenished.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, and 4 by Chen

  • Prior Art Relied Upon: Chen (Patent 5,822,524)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chen discloses every element of claims 1, 2, and 4. Chen describes a client-server system for streaming multimedia files over a network using data packets, each with a unique packet sequence number. The core of the argument centered on Chen’s “Water Mark” model for buffer management. This model uses high and low thresholds to control data transmission in different modes. When the client buffer’s data level is between the marks, transmission occurs in “Normal” mode at the playback rate. Crucially, when the data level falls below the low water mark, the system switches to “Rush” mode, where data is transmitted as fast as possible to refill the buffer—a rate inherently faster than the playback rate. This directly maps to the ’011 patent’s central feature. Chen further taught a client agent that manages the buffer, maintains a record of the last received packet’s serial number to detect packet loss, and repeatedly requests data elements to maintain a predetermined number of packets in the buffer until the entire program is received. Dependent claims 2 (computer adapted as a media player) and 4 (receiving data more rapidly than the playback rate) were argued to be expressly disclosed by Chen’s description of a client computer running a multimedia application and its use of the “Rush” mode, respectively.

Ground 2: Obviousness of Claim 3 over Chen in view of Rolf

  • Prior Art Relied Upon: Chen (Patent 5,822,524) and Rolf (Patent 7,065,342)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that claim 3, which adds the limitation that the media player of claim 1 is a “wireless phone,” is obvious over the combination of Chen and Rolf. Chen provided the complete streaming media buffering system as argued in Ground 1. Rolf disclosed a system for wirelessly transmitting encoded music and other media over the Internet to a portable communications device, explicitly identifying a “cellular telephone” as a primary embodiment. Rolf’s system involved a remote facility streaming content to a mobile device that includes a player.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to combine the teachings of Chen and Rolf. Applying Chen’s efficient and robust buffering and data retrieval system to a mobile device, as taught by Rolf, was presented as a predictable way to improve the quality and reliability of media streaming on wireless phones. The motivation was to expand the mobility and practical application of Chen’s high-performance streaming architecture to the growing market of mobile users, providing the benefit of smoother, higher-quality video playback on the go.
    • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success. The combination amounted to substituting the stationary client machine in Chen with the known mobile client device from Rolf. This was argued to be a straightforward application of a known streaming methodology to a known type of device to achieve a predictable improvement in performance, requiring no undue experimentation.

4. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-4 of the ’011 patent as unpatentable.