PTAB

IPR2016-01238

WebPower, Inc. v. WAG ACQUISITION, LLC

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1. Case Identification

2. Patent Overview

  • Title: STREAMING MEDIA BUFFERING SYSTEM
  • Brief Description: The ’141 patent is directed to systems and methods for buffering streaming media data over the Internet. The invention purports to solve issues with playback interruptions by having a server transmit data to a user at a rate more rapid than the playback rate when the user's buffer is not full, thereby ensuring the buffer remains sufficiently full for uninterrupted viewing.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-2, 4-7, 9-11, 13-16, 18-20, 23-24, and 26-28 under §102

  • Prior Art Relied Upon: Chen (Patent 5,822,524).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chen, which was not cited during prosecution, anticipates every limitation of the challenged claims. Chen allegedly disclosed a client-server architecture for streaming multimedia files where a client buffer's fill level is monitored using a "Water Mark" model. Petitioner contended that when Chen’s client buffer falls below a low water mark, the server transmits data in a "Rush" mode, which it described as "as fast as possible." This was asserted to be the same as the ’141 patent’s core concept of sending data at a rate "more rapid than the playback rate" to maintain buffer sufficiency. Furthermore, Petitioner argued Chen disclosed using unique packet sequence numbers as serial identifiers and having the client request specific data elements using these identifiers.

Ground 2: Obviousness of Claims 8, 17, and 21 over Chen in view of Willebeek

  • Prior Art Relied Upon: Chen (Patent 5,822,524) and Willebeek (IBM Journal of Research and Development, Mar. 1998).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring the server to obtain streaming media from a live source, a feature not explicitly taught in Chen. Petitioner asserted that Willebeek taught a system for streaming live audio and video using a "capture station" that receives a live feed, converts it to packetized data, and transfers it to a server "reflector." This reflector maintained a circular buffer containing the most recent data from the live transmission for streaming to new users.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSA) would have been motivated to combine Willebeek's live-source capability with Chen's server architecture. The motivation was to adapt the known functionalities of Chen's system to accommodate the "recently available" live streaming content that Willebeek described, representing a predictable expansion of an existing system's capabilities.
    • Expectation of Success: A POSA would have had a reasonable expectation of success because both systems operated in the same technical field and utilized compatible packetized data protocols. The combination would involve configuring Chen's server to use a copy of Willebeek's circular buffer for a user requesting a live stream, allowing it to initially "rush" data to the user and then continue streaming as new packets arrived from the live feed.

Ground 3: Obviousness of Claims 1-2, 4-9, 15, 24, and 26-27 over Carmel in view of Willebeek

  • Prior Art Relied Upon: Carmel (Patent 6,389,473) and Willebeek (IBM Journal of Research and Development, Mar. 1998).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Carmel and Willebeek rendered the claims obvious. Carmel allegedly disclosed most key limitations, including a system for real-time multimedia broadcasting where a data stream is divided into a sequence of indexed "slices." Carmel's server sent data at a rate faster than playback to overcome lag. Petitioner asserted that Willebeek supplied the remaining limitation: maintaining a sufficient data supply for uninterrupted playback by preloading data. Willebeek’s "Bamba player" software automatically calculated how much data to preload based on network conditions to ensure continuous playback.
    • Motivation to Combine: A POSA would combine these references because both addressed streaming media from live sources. The proposed combination involved using a known technique (Willebeek's client-side preloading and buffering logic) to improve a similar known device (Carmel's streaming architecture). The motivation was to achieve the predictable result of more robust, continuous playback, particularly when facing network congestion.
    • Expectation of Success: Applying Willebeek's client-side storage and preloading logic to the Carmel system was presented as a straightforward integration of a known buffering solution into a known streaming system, which would predictably enhance playback reliability.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds that claims were obvious over Carmel alone (anticipating claims 10-11, 13-21, and 23); over Chen in view of ISO-11172 (MPEG-1 standard) to teach constant bit rate encoding; and over combinations of Carmel, Willebeek, and ISO-11172.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-28 of the ’141 patent as unpatentable.