PTAB

IPR2017-00284

Amazon.com Inc v. Digital Media Technologies Inc

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Multimedia System and Method
  • Brief Description: The ’764 patent discloses a multimedia system for distributing digital content using a Digital Rights Management (DRM) scheme to manage access. The system involves an external control server, a content server, and a client device, and it uses encryption and license-based controls to protect content.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bi and Peinado - Claims 1-37 are obvious over Bi in view of Peinado.

  • Prior Art Relied Upon: Bi (WO 02/045316) and Peinado (Application # 2003/0078853).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bi teaches a general framework for a digital content distribution system with a client-server architecture, client authentication, and secure transmission, but it does not detail a specific DRM implementation. Bi’s system includes an application server to handle authentication and a license server to manage access rights. Peinado, in contrast, teaches a specific and compatible DRM solution that fills the gaps in Bi. Peinado discloses encrypting content with a symmetric key and then encrypting a content license (which contains both the symmetric key and usage parameters) using the client device's public key. This encrypted license is sent to the client, which uses its private key to decrypt the license and access the content according to the specified usage rights.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) implementing Bi's content distribution framework, which explicitly suggests using a DRM system, would look to known DRM solutions for implementation details. Petitioner asserted a POSITA would combine Bi with Peinado because Peinado provides a functional and compatible DRM system. The motivation was strengthened by a shared association with Microsoft; Bi references Microsoft’s Windows Media Rights Manager, and Peinado is a Microsoft patent application describing a similar DRM architecture.
    • Expectation of Success: A POSITA would have a high expectation of success because combining the references was merely the application of a known DRM technique (Peinado) to a known content distribution system (Bi) that expressly called for such a technique. Petitioner noted that the assignee of the Bi application, Full Audio Corporation, had commercially implemented a similar system using Microsoft’s DRM technology, demonstrating the predictability and viability of the combination.

Ground 2: Obviousness over Bi, Peinado, and Reisman - Claims 3-6, 8, 10, 11, 13-16, 22, 33, 35, and 37 are obvious over Bi and Peinado in view of Reisman.

  • Prior Art Relied Upon: Bi (WO 02/045316), Peinado (Application # 2003/0078853), and Reisman (Application # 2003/0229900).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Bi and Peinado combination to address dependent claims reciting specific client device types and network environments. Petitioner argued that to the extent Bi and Peinado do not explicitly disclose distributing content to certain devices (e.g., tablet computers, cellular telephones, game consoles) or over specific networks (e.g., wireless wide area or local area networks), Reisman provides the missing teachings. Reisman discloses methods for extending the delivery of DRM-protected content to a "rich array" of networked devices, including tablets, PDAs, cell phones, and game consoles, over various networks, including wireless LANs and cellular networks.
    • Motivation to Combine: Petitioner contended that Reisman addressed the well-understood market trend of making digital content available on a wide variety of popular consumer electronics. A POSITA seeking to broaden the applicability of the Bi/Peinado system to meet consumer demand would be motivated to incorporate Reisman’s teachings. Reisman itself suggests that its methods for extending content delivery are compatible with DRM, creating a clear motivation to apply its teachings to a DRM-enabled system like that proposed by the combination of Bi and Peinado.
    • Expectation of Success: Success would be expected because Reisman's teachings represented a natural and predictable extension of a content delivery system to known and emerging platforms. The combination amounted to making a known system (Bi/Peinado) available on more devices and networks as taught by Reisman, which was a common and straightforward design goal at the time.

4. Key Claim Construction Positions

  • Petitioner proposed a construction for the term "information related to a location of the content license" (claim 1) under the Broadest Reasonable Interpretation (BRI) standard.
  • Proposed Construction: "information that can be used to find license components."
  • Petitioner argued this construction was supported by the specification, which describes license components like a content key and a status file as potentially separate files. The phrase "related to" suggests the information is not the location itself but rather data, such as a content ID or URL, that the system uses to find the license.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-37 of Patent 8,964,764 as unpatentable under 35 U.S.C. §103.