PTAB

IPR2017-01049

Comcast Cable Communications LLC v. Rovi Guides Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Interactive Television Program Guide With Remote Access
  • Brief Description: The ’413 patent discloses a system featuring a remotely accessible interactive television program guide (IPG) that communicates over the Internet with a local IPG to schedule recordings on local hardware. A key aspect is that the remote guide, implemented on a mobile device, is generated based on a user profile stored at a location remote from the mobile device itself.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-10, and 12-18 are obvious over Sato in view of Humpleman.

  • Prior Art Relied Upon: Sato (Patent 6,408,435) and Humpleman (Patent 6,182,094).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sato taught the core limitations of the challenged claims. Sato disclosed an Internet-enabled system where a remote user, via an "external portable computer" (a mobile device), could access web-based program listings and send commands over the Internet to a local PC to schedule recordings on a VTR. Petitioner contended that the browsers on Sato’s local PC and remote computer function as the claimed "local" and "remote" interactive program guides, respectively. However, Sato did not explicitly teach generating the remote guide based on a user profile. To supply this limitation, Petitioner pointed to Humpleman, which disclosed a home network system that generates customized HTML program guides based on stored user preferences (e.g., filtering out disfavored channels). This customized guide could be accessed remotely over the Internet.
    • Motivation to Combine: A POSITA would combine Humpleman's user preference features with Sato's remote recording system to achieve a predictable improvement. The combination would use a known technique (user customization) to enhance a similar system (remote guide access), predictably resulting in a better user experience by allowing users to more easily find desired content and limiting the data transferred to the remote device.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved the simple substitution of a known, closely-related feature (Humpleman's customized guide pages) for another (Sato's standard web pages) to obtain predictable results.

Ground 2: Claims 1, 3-10, and 12-18 are obvious over Woo in view of Mizuno and Rzeszewski.

  • Prior Art Relied Upon: Woo (Patent 5,485,219), Mizuno (WO 97/18636), and Rzeszewski (Patent 5,699,125).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Woo disclosed a system with a local IPG that allowed users to schedule recordings remotely, but did so via a manual process of phoning a human operator at a central control station. To automate this outdated manual step, Petitioner combined Woo with Mizuno. Mizuno taught a system that served HTML-based remote program guides over the Internet, allowing users on any suitable device to remotely control home equipment like VCRs, thereby replacing the human operator with a web interface. To meet the "user profile" limitation, Petitioner further added Rzeszewski, which taught a conventional "favorite station" feature that displays a guide of user-selected channels based on stored user profile information.
    • Motivation to Combine: A POSITA would have been motivated to replace Woo's inefficient manual call-in process with Mizuno's well-known automated web-based remote access solution to reduce costs and inconvenience. Subsequently, a POSITA would have incorporated the common "favorites" feature from Rzeszewski into the combined Woo-Mizuno system to improve its functionality, a predictable enhancement that would help users locate desired programs more efficiently.
    • Expectation of Success: The proposed modifications involved automating a manual process and adding a conventional feature, both of which were well-understood techniques at the time. A POSITA would have reasonably expected that replacing a human operator with a web interface and adding a favorites list would function as intended.

  • Additional Grounds: Petitioner asserted that claims 2 and 11, which require recording at a "television distribution facility," were obvious over the primary combinations of Sato/Humpleman and Woo/Mizuno/Rzeszewski with the further addition of Lawler (Patent 5,805,763). Lawler taught the advantages of a centralized recording system at a network headend as a substitute for local recording.

4. Key Claim Construction Positions

  • "local interactive television program guide": Petitioner argued that, under the broadest reasonable construction, this term refers to an IPG that generates a display for use at the user's premises. Crucially, Petitioner requested the Board to adopt the Patent Owner's own broad interpretation from a parallel ITC investigation, wherein the "local guide" could be implemented on equipment that includes servers located outside the user's home. This construction was central to Petitioner's argument that prior art references like Sato, where guide data is served from an external broadcast station to a local PC, meet the claim limitation.
  • "user profile": Petitioner proposed that the broadest reasonable construction of a "user profile" is any data indicating a user preference. This broad construction allowed Petitioner to argue that features like stored "favorite channels" (from Rzeszewski) or customized HTML pages based on filtered content (from Humpleman) satisfied the claim limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-18 of the ’413 patent as unpatentable under 35 U.S.C. §103.