PTAB

IPR2017-00944

Comcast Cable Communications LLC v. Veveo Inc

Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method and System for Performing Searches for Television Content Using Reduced Text Input
  • Brief Description: The ’218 patent discloses a method for incrementally searching a large set of television content items. The system identifies content items that have one or more associated descriptors matching a string of prefixes entered by a user, dynamically updating results as each character is input.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gross and Robarts - Claims 1-7, 9-13, 17-25, 27-31, and 35-36 are obvious over Gross in view of Robarts.

  • Prior Art Relied Upon: Gross (Application # 2004/0133564) and Robarts (Patent 8,051,450).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gross taught a general-purpose incremental search system that pre-indexes content, including data for interactive television networks, based on both whole words and prefixes. Gross further disclosed ranking results using pre-computed sort lists. While Gross provided the core search mechanism, Robarts supplied the specific context of an Electronic Program Guide (EPG) with a large database of television content items, a problem domain where efficient searching is critical.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Gross's established prefix indexing and search system with Robarts's television-specific EPG database. This combination represented the application of a known, general-purpose search technique to a known and analogous problem (searching large EPGs) to achieve the predictable result of an efficient prefix-based search for television content.
    • Expectation of Success: The combination involved applying known elements for their intended purposes, leading to a high expectation of success in creating a more efficient EPG search tool.

Ground 2: Obviousness over Robarts and Zigmond - Claims 1-2, 4-7, 9, 11-13, 17-20, 22-25, 27, 29-31, and 35-36 are obvious over Robarts in view of Zigmond.

  • Prior Art Relied Upon: Robarts (Patent 8,051,450) and Zigmond (Application # 2005/0256846).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Robarts taught searching an EPG based on user input but did not explicitly disclose pre-associating content items with prefixes of descriptive terms. Zigmond was argued to supply this by teaching a system that pre-maps content into discrete "bins" corresponding to every possible prefix of words in a title. This pre-mapping was explicitly for the purpose of reducing latency in search-as-you-type systems.
    • Motivation to Combine: A POSITA would modify Robarts's EPG search system by incorporating Zigmond's prefix pre-mapping technique. The primary motivation was to improve system efficiency and enhance the user experience by speeding up search query responses—a well-understood design goal for interactive systems.
    • Expectation of Success: Implementing Zigmond's known optimization technique within Robarts's established EPG framework was a predictable modification that would have worked as expected to reduce search latency.

Ground 3: Obviousness over Gross, Robarts, and Thomas - Claims 8 and 26 are obvious over Gross in view of Robarts and in view of Thomas.

  • Prior Art Relied Upon: Gross (Application # 2004/0133564), Robarts (Patent 8,051,450), and Thomas (Application # 2003/0093794).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the base combination of Gross and Robarts to address dependent claims 8 and 26, which added the limitation of a relevance function comprising "location relevance." Petitioner asserted that while Gross and Robarts provided the core search system, Thomas explicitly taught a system that identifies the location relevance of television news programs and ranks a list of shows based on that location data.
    • Motivation to Combine: A POSITA would have been motivated to add the location-based ranking taught by Thomas as an additional relevancy feature to the base search system of Gross/Robarts. This represented a simple combination of known elements to yield the predictable result of improved, more relevant search results for the user.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Sanders (for stop-word handling) and Brown (for phonetic and misspelling matching) to address other specific dependent claim limitations. These grounds relied on similar motivations of combining known search features to improve the user experience and search efficiency.

4. Key Claim Construction Positions

  • "the first and second prefixes are in an ordered format/unordered format": Petitioner proposed this term meant that the sequence of prefixes either must be maintained ("ordered") or need not be maintained ("unordered") between the search query and the resulting content items. This construction was central to mapping prior art that taught functionalities like exact phrase matching (for "ordered" format) or Boolean "AND" searches (for "unordered" format).
  • "stop words": Petitioner construed this term to mean common natural language words (e.g., "a," "an," "the") that are typically ignored by search engines during indexing and querying to improve efficiency. This construction was necessary to apply prior art, such as Sanders, that explicitly taught identifying and removing such words from descriptive terms to speed up processing.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-36 of Patent 7,895,218 as unpatentable under 35 U.S.C. §103.