PTAB

IPR2017-00288

Samsung Electronics Co Ltd v. Personalized Media Communications LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: SIGNAL PROCESSING APPARATUS AND METHODS
  • Brief Description: The ’217 patent discloses methods and apparatuses for coordinating and outputting multimedia presentations. A receiver station receives signals containing at least two media, determines the content of one medium by processing and comparing identifiers, and coordinates a combined multimedia presentation for display to a user.

3. Grounds for Unpatentability

Ground 1 & 2: Obviousness over Campbell in view of Hilbert - Claims 1-5, 7-9, 11, 30-32, and 38 are obvious over Campbell-A or Campbell-B in view of Hilbert.

  • Prior Art Relied Upon: Campbell-A (WO 81/02961), Campbell-B (Patent 4,536,791), and Hilbert (Patent 4,051,532). Petitioner asserted that Campbell-A and Campbell-B contain completely overlapping disclosures and presented the grounds contingently.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Campbell discloses an addressable cable television system that meets the core limitations of the challenged claims. In Campbell’s system, a head-end station transmits standard television program signals (the second medium) combined with supplemental digital data, such as text and graphics (the first medium), embedded within the signal’s vertical blanking interval (VBI). This VBI data constitutes a "digital data channel." At a subscriber’s receiver station, an addressable converter—a "computer" under the patent's broadest reasonable interpretation—receives the combined signal. The converter’s control logic, which includes a microprocessor, extracts the digital data from the VBI and stores it in a display memory.
    • Petitioner mapped Campbell's access control mechanism to the claim limitation of "determining content" by "comparing" identifiers. Campbell's system transmits control codes (e.g., program eligibility/rating codes) within the VBI. The receiver station's converter compares these program codes against predetermined subscriber authorization codes (e.g., an eligibility threshold) to determine if the user is permitted to view the selected program. Petitioner asserted this comparison of codes to determine the suitability of the program's content (e.g., its rating) constitutes processing an identifier to determine content.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would have been motivated to combine Campbell with Hilbert to enhance Campbell's system with a well-known feature. Campbell explicitly teaches that its supplemental VBI data can be used to "supplement a channel television program." Hilbert teaches a system for inserting an "auxiliary signal" into a standard video signal to provide supplemental information, specifically citing "subtitles for deaf persons" as a desirable feature. Hilbert further teaches superimposing this information onto the program picture. A POSITA would combine these teachings to use Campbell's VBI data-delivery mechanism to transmit subtitles, as taught by Hilbert, and then superimpose them over the main video program. This combination would achieve the stated goal of both references: supplementing a television program with additional, relevant information.
    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success in making this combination. Campbell’s disclosed text/graphics generator is already capable of superimposing text (e.g., channel numbers) onto the video display. Modifying this existing component to superimpose subtitles extracted from the VBI would be a predictable and straightforward design choice. Furthermore, Campbell's system supported a data transfer rate of approximately 240 characters per second, which is more than sufficient to transmit readable subtitles, making the integration technically feasible using known methods.

4. Key Claim Construction Positions

  • "medium" / "media": Petitioner argued that under the broadest reasonable interpretation, these terms should encompass "forms of electronically transmitted programming, such as audio, video, graphics, and/or text." This construction was asserted to be consistent with the patent's specification, which refers to television and radio as "mass media," and was also the construction reached by the district court in co-pending litigation.
  • "computer": Petitioner proposed that "computer" should be construed as "a programmable electronic device that can store, retrieve, and process data." This position was based on dictionary definitions from the relevant time and the patent's own description of the receiver station's "microcomputer" as a conventional, preprogrammed device configured to perform specific tasks.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-5, 7-9, 11, 30-32, and 38 of the ’217 patent as unpatentable.