PTAB

IPR2016-01555

Samsung Electronics Co Ltd v. TiVo Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Multimedia Signal Processing System
  • Brief Description: The ’476 patent relates to a system for the real-time capture, storage, and display of television broadcast signals. The disclosed system architecture includes an input section that produces an MPEG transport stream, a processor, a decoder/graphics subsystem, a storage subsystem, and a media switch that manages data flow between components.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1 and 6-10 under 35 U.S.C. §102

  • Prior Art Relied Upon: MacInnis (Patent 6,853,385).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that MacInnis, which discloses an integrated circuit for processing and displaying video and graphics, teaches every element of independent claim 1 and dependent claims 6-10. MacInnis’s system includes an input section for acquiring MPEG-2 transport streams, a CPU, and a decoder subsystem. Petitioner contended that MacInnis’s graphics accelerator and system bridge controller collectively function as the claimed "media switch," as they mediate data flow between the CPU, memory (storage subsystem), and other components, and operate asynchronously from the CPU. Furthermore, Petitioner asserted that the simultaneous storage and retrieval limitation is met by MacInnis’s disclosure of a transport recorder and a playback circuit (PVR) with two separate channels, allowing one channel to store data while the other retrieves it.

Ground 2: Obviousness of Claims 1, 6-10, and 13 under 35 U.S.C. §103

  • Prior Art Relied Upon: MacInnis (Patent 6,853,385).
  • Core Argument:
    • Prior Art Mapping: As an alternative to Ground 1, Petitioner argued MacInnis renders the claims obvious. For claim 13, which adds a "front panel navigation cluster coupled to a GPIO," Petitioner asserted that MacInnis’s I/O bus bridge with DMA is a general-purpose input/output interface.
    • Motivation to Combine (Modify): A POSITA would find it obvious to couple a common input device like a keyboard (which Petitioner equated to a "front panel navigation cluster") to MacInnis’s general-purpose I/O bus bridge. The motivation would be to provide user control for system development, debugging, or marketing. For the limitation of simultaneous data storage and retrieval, Petitioner argued that to the extent it is not explicitly disclosed, a POSITA would have been motivated to modify MacInnis’s memory architecture to a dual-controller system (also taught in MacInnis) to allow for the disclosed goal of concurrent memory access by different clients.
    • Expectation of Success: Success would be expected, as this involves coupling a standard peripheral to a general-purpose port and implementing a disclosed memory architecture to improve performance.

Ground 3: Obviousness of Claims 11 and 14 under 35 U.S.C. §103

  • Prior Art Relied Upon: MacInnis (Patent 6,853,385) and Meandzija (WO 00/24192).
  • Core Argument:
    • Prior Art Mapping: This ground challenged claims reciting a processor operative to run "system software, middleware, and application software." Petitioner argued that while MacInnis discloses a CPU that implements software functions, it does not explicitly detail these software layers. Meandzija discloses a software architecture framework for a television set-top box that explicitly teaches these three distinct layers: an operating system (system software), a middleware layer, and a native applications layer.
    • Motivation to Combine: A POSITA would combine Meandzija’s established software architecture with MacInnis’s hardware system to create a fully functional set-top box. Meandzija’s framework was designed for integration with various processors and operating systems, making it a natural choice for implementation on the MacInnis hardware. This combination would allow for easier integration and more efficient development of advanced software functionalities.
    • Expectation of Success: A POSITA would have a high expectation of success in implementing a known software architecture on a suitable hardware platform like that described in MacInnis.

4. Key Claim Construction Positions

  • media switch: Petitioner adopted the Patent Owner’s proposed construction of "hardware and/or code that mediates between a microprocessor CPU, hard-disk or storage device, and memory." This construction was central to arguing that components like the graphics accelerator and system bridge in MacInnis meet the limitation.
  • front panel navigation cluster: Petitioner adopted the construction of "exterior buttons or keys to control the device." This broad construction supported the argument that a common keyboard would meet the limitation in claim 13.

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention of the petition was that the challenged claims of the ’476 patent were not entitled to the earlier filing dates of the parent ’389 patent or the ’856 provisional application. Petitioner argued that key limitations of claim 1—specifically the inclusion of a "host controller," a "bus arbiter," and a "multimedia data stream processor" as components of the "media switch"—lacked the necessary written description support in the earlier applications. By establishing a later effective filing date for the challenged claims, Petitioner positioned MacInnis and Meandzija as valid prior art under §102.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 6-11, 13, and 14 of the ’476 patent as unpatentable.