PTAB

IPR2017-00811

Amazon.com Inc v. Broadcom Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Media Processing System Supporting Different Media Formats Via Server-Based Transcoding
  • Brief Description: The ’295 patent discloses a system for reformatting media content for a destination device when the source device is unaware of the destination device's format capabilities. The system uses a first server to receive a device profile and a second server to receive and transcode media content based on that profile.

3. Grounds for Unpatentability

Ground 1: Anticipation over Bhagwat - Claims 1-6, 8-12, 19-23, and 25-27 are anticipated by Bhagwat.

  • Prior Art Relied Upon: Bhagwat (European Patent Application Publication No. 0992922).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bhagwat disclosed every element of the challenged claims. Specifically, Bhagwat’s system for reformatting web content included an "HTTP proxy engine 220" that functioned as the claimed "first server" and an "object transcoder 240" that functioned as the "second server." Bhagwat's "client 230" was identified as the "first communications device," which sent its device profile (as user preferences and display capabilities) to the proxy engine. Bhagwat's "web server 210" was identified as the "second communications device," which sent media content to the proxy engine. The petition asserted that Bhagwat’s transcoder (second server) received this media content from the proxy engine (first server) and reformatted it based on the client's device profile, thus meeting all limitations of independent claims 1 and 12.
    • Key Aspects: Petitioner contended that Bhagwat’s disclosure of a "transcoding proxy system" inherently described the claimed two-server architecture, where the proxy engine and transcoder are distinct functional servers, even if co-located.

Ground 2: Anticipation over Egli - Claims 12, 19-22, and 25-27 are anticipated by Egli.

  • Prior Art Relied Upon: Egli (Application # 2003/0110234).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended Egli disclosed a media delivery system that anticipated the method claims. Egli’s "Client Capabilities Module (CCM) 322" was argued to be the claimed "first server," as it received device profile information from a "client device 301" (the first communications device). Egli's "Media Transformation Module (MTM) 325" was mapped to the "second server," which was operatively coupled to the CCM. The petition argued that the MTM received media content destined for the client device and reformatted it based on the device profile information provided by the CCM, thereby teaching all steps of independent claim 12. The "internet site (server) 330" in Egli was identified as the source of media content (the second communications device).

Ground 3: Obviousness over Bhagwat and Kirani - Claims 13-14, 16-18, and 24 are obvious over Bhagwat in view of Kirani.

  • Prior Art Relied Upon: Bhagwat (European Patent Application Publication No. 0992922) and Kirani (WO 01/86511).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Bhagwat taught nearly all elements of the base claims, but Kirani was introduced to supply missing limitations in certain dependent claims. Specifically, Kirani was cited for its teaching of a second communications device (a "photoserver") sending a first communications device's profile to a server. While Bhagwat taught the first device sending its own profile, Kirani taught a server-side component managing and sending profiles. Kirani was also cited for its teaching of a first communications device sending media content directly to a second server for storage, a feature not explicitly in Bhagwat.
    • Motivation to Combine: A POSITA would combine Kirani’s profile management system with Bhagwat’s transcoding system to improve performance and data availability. Storing and managing device profiles on a server (like Kirani’s photoserver, analogous to Bhagwat’s web server) rather than relying solely on the client device was presented as a predictable design choice. Similarly, a POSITA would find it obvious to add media storage capability to Bhagwat’s second server (transcoder) for caching, as taught by Kirani, to improve efficiency.
    • Expectation of Success: The combination involved applying known network design principles—such as centralized profile management and server-side caching—to a known system, which would have provided a POSITA with a reasonable expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 7 and 15 over combinations including Su (Application # 2002/0199190) for its teaching of using headends to couple devices to a network. Further grounds combined Egli with Bhagwat, Kirani, and Su, relying on similar motivations to substitute or add features, such as Bhagwat's efficient caching architecture into Egli's system.

4. Key Claim Construction Positions

  • "server": Petitioner proposed that for the purposes of the IPR, "server" should be construed to mean "computer equipment or software that provides one or more services." This construction was argued to be consistent with the patent’s disclosure and necessary to recognize that functional software modules like Bhagwat's "HTTP proxy engine" and "object transcoder" or Egli's "CCM" and "MTM" met the claim limitations for the first and second servers.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-27 of the ’295 patent as unpatentable.