PTAB

IPR2017-00290

Samsung Electronics Co Ltd v. Personalized Media Communications LLC

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: SIGNAL PROCESSING APPARATUS AND METHODS
  • Brief Description: The ’649 patent describes methods for processing television or video signals at a receiver station. The system involves embedding digital information within a broadcast transmission, which is then detected and used by processors at the receiver to control various functions and the presentation of information.

3. Grounds for Unpatentability

Ground 1: Obviousness over Campbell - All Challenged Claims are obvious over Campbell in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Campbell-1A (WO 81/02961) and Campbell-1B (Patent 4,536,791), collectively referred to as "Campbell."
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Campbell disclosed all elements of the challenged claims. Campbell’s system, comprising a converter and a television, functioned as the claimed “receiver station” with a “plurality of processors” (e.g., video descrambler, text generator, audio control). Petitioner asserted Campbell taught receiving an information transmission (a cable TV signal) that included a “digital television signal” and a “message stream,” which were mapped to the digital data transmitted within the vertical blanking interval (VBI) of the analog video signal. Campbell’s vertical interval data extractor detected this message stream, and its control processor selected control information (e.g., program tier codes) from the stream to control the other processors. Based on this control information, other portions of the message stream (e.g., text/graphics data) were output to the video and audio processors to control the presentation of television programming.
    • Motivation to Combine: The ground relied on combining the teachings of Campbell with the general knowledge of a person of ordinary skill in the art (POSITA). For instance, Petitioner argued that implementing certain functions, such as using register memories to temporarily store control data for comparison, was a well-known technique to improve processing speed. A POSITA would have found it a commonsense and obvious design choice to use the register memories included in the conventional microprocessors disclosed by Campbell for this purpose.
    • Expectation of Success: A POSITA would have had a high expectation of success in applying common knowledge to Campbell’s system. The modifications, such as using standard processor interrupts for signaling or implementing logic on a single microchip, involved applying predictable and well-established principles to the disclosed architecture without changing its fundamental operation.

Ground 2: Obviousness over Campbell and Widergren - All Challenged Claims are obvious over Campbell in view of Widergren.

  • Prior Art Relied Upon: Campbell (as defined in Ground 1) and Widergren (Patent 4,302,775).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative in the event the claims were construed to require a completely digital signal, rather than a hybrid analog signal with embedded digital data. Petitioner argued that Campbell taught the core signal processing architecture and control logic, while Widergren taught a system for converting a standard analog NTSC television signal into a fully digital data stream for transmission and then converting it back to analog for display. Petitioner contended that a POSITA would have replaced the analog signal paths in Campbell’s system with the fully digital transmission and reception paths taught by Widergren.
    • Motivation to Combine: A POSITA would combine Campbell and Widergren to create a fully digital television system to achieve known benefits over analog or hybrid systems. These benefits included superior noise immunity, increased data capacity, and the ability to implement more robust and secure signal scrambling. Widergren explicitly provided the necessary components for digital conversion and compression, which would allow Campbell’s system to operate over a limited bandwidth medium in a more efficient and robust manner.
    • Expectation of Success: The combination would have yielded predictable results. Both Campbell and Widergren operated on standard NTSC video and audio signals, making the integration of their respective technologies straightforward. A POSITA would have understood how to modify Campbell’s signal processors to interface with Widergren’s digital transmission components (e.g., compressor and expander) to create a functional and improved system.

4. Key Claim Construction Positions

  • "digital television signals": Petitioner proposed the construction "television signals entirely or partially encoded in a digital format." This construction was critical because it allowed the hybrid signal in Campbell, which embeds digital data in the VBI of an otherwise analog television signal, to satisfy the claim limitation. This interpretation was supported by the patent’s prosecution history, where the applicant made similar arguments.
  • "processor": Petitioner proposed the construction "a device that operates on data." This broad definition was important for the invalidity arguments, as it allowed various components in Campbell’s disclosed system—including hardwired devices like decoders and text generators, not just a central CPU—to be considered "processors" as required by the claims.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-3, 7, 8, 11, 13, 26-29, 39, 41, 42, 45, 48-51, 62-64, 67, 78, 82-84, 88, and 90-94, 97 as unpatentable.