PTAB

IPR2017-00291

Samsung Electronics Co Ltd v. Personalized Media Communications LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: SIGNAL PROCESSING APPARATUS AND METHODS
  • Brief Description: The ’650 patent relates to methods for processing television and video signals at a receiver station. The system involves receiving a broadcast transmission containing embedded digital information, which is used to program processors within the receiver to perform specific functions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mustafa - Claims 1, 2, 4, 18, 32, and 33 are obvious over Mustafa.

  • Prior Art Relied Upon: Mustafa (Patent 4,789,895).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mustafa teaches a method of television signal processing where a receiver terminal processes signals containing video frames, digitally encoded audio, and encoded audio channels. The preamble limitations of a "plurality of processors" and a "digital switch" were met by Mustafa’s various output processors (e.g., for video and audio) and its Vertical Blanking Interval (VBI) Processor, which receives digital inputs and directs them to the appropriate output processor. Petitioner mapped each step of claim 1, arguing that Mustafa’s transmission of audio/video frame data is divided into a "message stream" (auxiliary information like terminal address and mode codes) and "digital television signals" (active lines with video and digitally encoded audio data). The VBI Processor in Mustafa allegedly functions as the claimed switch, controlled by commands in the message stream to route signal segments to the correct processors.
    • Motivation to Combine (for §103 grounds): This ground is a single-reference obviousness challenge, asserting that Mustafa alone renders the claims obvious to a Person of Ordinary Skill in the Art (POSITA).
    • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

Ground 2: Obviousness over Mustafa in view of Iijima - Claims 1, 2, 4, 18, 32, and 33 are obvious over Mustafa in view of Iijima.

  • Prior Art Relied Upon: Mustafa (Patent 4,789,895) and Iijima (Patent 4,215,369).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative in case the term "digital television signals" is construed to mean completely digital signals. While Mustafa transmits standard NTSC television formats, Iijima discloses a digital transmission system that converts analog NTSC video signals to digitized signals for transmission and converts them back at the receiver. Petitioner argued that a POSITA would have found it obvious to replace the analog signal paths in Mustafa’s system with the digital encoding/decoding system taught by Iijima. The resulting combination would be a fully digital transmission system that still performs all the processing steps disclosed in Mustafa.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Mustafa and Iijima to create a fully digital television system. The motivation stemmed from the known advantages of digital signals over analog, such as better immunity to noise and improved signal quality.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because both references describe systems for transmitting and receiving standard NTSC television signals, making Iijima’s digital conversion technology directly applicable to Mustafa’s signal processing architecture.

Ground 3: Obviousness over Campbell - Claims 1, 2, 4, 18, 32, and 33 are obvious over Campbell in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Campbell (primarily Patent 4,536,791 and International Publication No. WO 81/02961).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Campbell teaches a cable television system where a receiver converter processes a combined television and data signal. Digital control data, transmitted within the VBI, is used to control access to programming. Petitioner mapped the "plurality of processors" to Campbell's video descrambler, text/graphics generator, and audio level control. The "digital switch" was mapped to the microprocessor within Campbell's converter control logic, which receives the VBI message stream and directs the operation of the various processing modules. Campbell’s system allegedly receives an information transmission (claim 1[a]) including digital television signals (program content) and a message stream (VBI data) and uses commands in the stream to select and process the signals.
    • Motivation to Combine (for §103 grounds): This ground relied on the teachings of Campbell combined with the general knowledge of a POSITA, asserting all claim elements were present in or made obvious by Campbell's disclosure.
    • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge based on Campbell in view of Widergren (Patent 4,302,775) as an alternative ground if the claims are construed to require fully digital signals.

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 argued to be consistent with the prosecution history, where the applicant stated the term merely required "the usage of digital data in a television signal." This broader construction is critical to the applicability of prior art like Mustafa, which uses standard television formats that are not fully digital.
  • "processor": Petitioner proposed the construction "a device or module that operates on analog or digital signals." This broad construction avoids limiting the term to only digital microprocessors. Petitioner argued it was consistent with the term's well-known meaning in the art and supported by PTAB decisions in related cases, which recognized that components operating on both analog and digital information could collectively form a "processor."

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1, 2, 4, 18, 32, and 33 of the ’650 patent as unpatentable.