PTAB

IPR2017-00285

Amazon.com Inc v. Digital Media Technologies Inc

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1. Case Identification

2. Patent Overview

  • Title: Multimedia Management System
  • Brief Description: The ’657 patent discloses a system for distributing protected multimedia content using a Digital Rights Management (DRM) scheme. The system uses external control and content servers to manage user subscriptions, validate client devices, and deliver encrypted content and associated licenses to authorized users.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bi and Peinado - Claims 1-3, 5-24, 27-28, 30-32, and 34-55 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 Bi provides a complete framework for a client-server digital content distribution and subscription system but does not specify a particular DRM implementation. Bi teaches using an "application server" (external control server) and a separate "content server" to manage user authentication, process content requests, and deliver content. Peinado, a contemporaneous Microsoft application, was argued to disclose the specific DRM architecture and methods that Bi’s system suggests implementing. Peinado teaches a license server that validates device information against lists of acceptable devices, encrypts a content license using a client’s public key, and transmits the encrypted license to the client to enable decryption and consumption of protected content according to defined usage rules.
    • Motivation to Combine: A POSITA implementing Bi’s system would be motivated to look for a compatible DRM solution. Bi explicitly references Microsoft Windows Media Rights Manager, and Peinado describes a compatible DRM system in a Microsoft patent application. Petitioner asserted a POSITA would have naturally combined Peinado's DRM teachings with Bi’s content distribution framework to provide a complete, secure system. The shared Microsoft ecosystem context provided a strong motivation for the combination.
    • Expectation of Success: A POSITA would have a high expectation of success, as the assignee of Bi (FullAudio Corporation) commercially operated a digital music service that utilized Microsoft DRM technology, demonstrating the practical and predictable integration of these technologies before the patent's priority date.

Ground 2: Obviousness over Bi, Peinado, and Reisman - Claim 26 is 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 combination of Bi and Peinado to address claim 26, which adds limitations for protected content comprising an "interactive computer program" (e.g., a video game) executed by the client. Reisman was argued to teach DRM protection for media content resources such as video games delivered to and played on game consoles and other networked devices.
    • Motivation to Combine: A POSITA would combine Reisman with the Bi/Peinado system to extend DRM protection to interactive computer programs. Petitioner argued this was a predictable application of the core DRM technology to a different, but equally valuable, type of copyrighted content, addressing the known need for anti-piracy measures for video games.

Ground 3: Obviousness over Bi, Peinado, and Meffert - Claims 25 and 29 are obvious over Bi and Peinado in view of Meffert.

  • Prior Art Relied Upon: Bi (WO 02/045316), Peinado (Application # 2003/0078853), and Meffert (Application # 2002/0059144).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims 25 and 29, which require the client to communicate a content usage history to the control server, which then logs that information. Meffert disclosed a DRM system with a "trial play" functionality where a client-side agent maintains a local log file of content usage (e.g., number of plays). Meffert further taught that this local log file can be synchronized with the server of the content provider.
    • Motivation to Combine: A POSITA would be motivated to add Meffert’s teachings to the Bi/Peinado system to enhance it with features like trial plays or to improve usage tracking for subscription services. Synchronizing a a local usage log with a central server as taught by Meffert was presented as a known method for implementing such features.

Ground 4: Obviousness over Bi, Peinado, and Pasieka - Claims 4 and 33 are obvious over Bi and Peinado in view of Pasieka.

  • Prior Art Relied Upon: Bi (WO 02/045316), Peinado (Application # 2003/0078853), and Pasieka (WO 2000/074301).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claims 4 and 33, which require a public key to be generated by a "software plug-in" on the client. While Peinado taught generating key pairs on a server, Pasieka taught a method for more securely creating public/private key pairs by having the client device itself perform the generation based on parameters sent from a server.
    • Motivation to Combine: A POSITA would have been motivated to modify Peinado’s DRM system with Pasieka’s client-side key generation method to improve security. Generating the key pair on the client avoids transmitting the sensitive private key over the network, thereby preventing interception and yielding a known, predictable security benefit.

4. Key Claim Construction Positions

  • "software plugin" (claims 4 and 33): Petitioner proposed this term be construed as "processor-executable software on the client." This construction was based on the Patent Owner's own arguments during prosecution to overcome a §112 rejection, where the Patent Owner equated the client’s capabilities with "processor-executable software on the client."
  • "means for..." limitations (claim 55): For the various means-plus-function limitations in claim 55 (e.g., "means for receiving," "means for validating"), Petitioner argued that the corresponding structure disclosed in the specification is a "server that communicates over a network."

5. Relief Requested

  • Petitioner requested the Board institute an inter partes review and cancel claims 1-55 of the ’657 patent as unpatentable under 35 U.S.C. §103.