PTAB

IPR2017-00890

Microsoft Corp v. US Philips Corp

Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Transmitting Device For Transmitting A Digital Information Signal Alternately In Encoded Form And Non-Encoded Form
  • Brief Description: The ’695 patent discloses a system for transmitting and receiving a composite digital signal composed of both encoded and non-encoded portions. An identification signal is added to the composite signal to instruct the receiver on which portions require decoding and which should be passed through unmodified.

3. Grounds for Unpatentability

Ground 1: Obviousness over CCSDS and CCSDS Blue - Claims 14, 15, and 17

  • Prior Art Relied Upon: CCSDS (Consultative Committee for Space Data Systems Green Book, May 1997) and CCSDS Blue (a related CCSDS Blue Book, May 1997).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that CCSDS teaches a system for selectively compressing data for space-to-ground communication, including a “No Compression” option. For each data block, an ID bit pattern is selected to identify the chosen compression option (including no compression) for the decoder. The receiver’s “Ground Segment” includes a packet demultiplexer that separates the data from Application Process Identifiers (APIDs). CCSDS Blue, a related standard, discloses that a Compression Identification Packet (CIP) associated with an APID signals whether the data is compressed (first type of identification signal) or uncompressed (second type). This information acts as a control signal for a decompression processor, which either decodes the data or, if the ID bits indicate no compression, bypasses the decoder.
    • Motivation to Combine: A POSITA would combine the teachings because CCSDS explicitly references CCSDS Blue, both were issued by the same committee in the same month, and they describe the same data compression system.
    • Expectation of Success: The references are interoperable parts of a single, defined data transmission standard, ensuring a high expectation of success.

Ground 2: Obviousness over Clark - Claims 14 and 15

  • Prior Art Relied Upon: Clark (Patent 5,177,480).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Clark discloses a data transmission system with a transmitter and receiver switchable between a “compression mode” and a “transparent mode” (unencoded). The transmitter sends an explicit control codeword to the receiver to signal a transition to transparent mode. The receiver’s decoder receives this composite signal (data and control code) and uses a bypass switch to either decode the data or pass it through unmodified. This bypass switch, controlled by signals derived from the transmitted data, was argued to perform the functions of the claimed demultiplexing and decoding means. The control codeword for switching to transparent mode serves as an identification signal of a second type, while the receiver’s “transparency check” mechanism, which monitors data to switch back to compression mode, generates an identification signal of a first type.
    • Motivation to Combine (Implicit): Clark is a single reference that allegedly discloses all limitations. Petitioner further argued that it was known at the time to use a header to indicate compression status, and a POSITA would find it obvious to modify Clark’s specific implementation to use this simpler, known technique, which still meets the claim limitations.

Ground 3: Obviousness over Venbrux - Claims 14 and 15

  • Prior Art Relied Upon: Venbrux (an IEEE publication on lossless data compression).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Venbrux teaches a compression system using the Rice algorithm that selects one of twelve encoding options, including a “Default” non-encoded option, for each data block. “ID bits” identifying the chosen option are prepended to the data, forming a composite signal. The receiver’s “un-packer” and decoder constitute the claimed receiver. An “ID Decode” unit in the decoder derives the ID bits (the identification signal) from the composite signal and generates a “Control” signal. This control signal directs the data to the appropriate decoding pipeline (for a first type signal) or to the “Default” path, which bypasses decoding (for a second type signal).
    • Motivation to Combine (Implicit): Venbrux is a single reference that allegedly discloses all limitations of claims 14 and 15.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claim 17 over Clark in view of Bliss (Patent 6,009,549) and over Venbrux in view of Bliss. These grounds argued that a POSITA would have been motivated to add the well-known channel decoding and error detection/correction components taught by Bliss to the systems of Clark or Venbrux to improve reliability when reading data from a mass storage device, as claim 17 requires.

4. Key Claim Construction Positions

  • Petitioner argued for constructions of several means-plus-function terms under pre-AIA 35 U.S.C. § 112, ¶ 6. These constructions were central to mapping the prior art onto the claims.
  • “demultiplexing means for deriving at least one signal portion...and for deriving a first identification signal...” (claim 14): Petitioner identified the corresponding structure as “demultiplexer unit 62 and its equivalents.”
  • “decoding means for decoding...and to supply...” (claim 14): Petitioner identified the corresponding structure as “decoding unit 76, including decoder element 77, and equivalents.” This structure performs the dual functions of decoding data based on a first control signal and supplying data unmodified based on a second control signal.
  • “means for generating the control signal...” (claim 14): Petitioner identified the corresponding structure as “identifier unit 70 and its equivalents,” which derives control signals from the identification signal.

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 14, 15, and 17 of the ’695 patent as unpatentable under 35 U.S.C. § 103.