PTAB

IPR2017-01066

Comcast Cable Communications LLC v. Rovi Guides Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Interactive Television Program Guide With Remote Access
  • Brief Description: The ’801 patent describes a system enabling a user to remotely schedule television program recordings. The system features a remote guide on a user's remote device that communicates via the Internet with a local guide on the user's home equipment to set recordings.

3. Grounds for Unpatentability

Ground 1: Claims 1-54 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 disclosed the core architecture of the claimed invention, including an Internet-enabled system with a local guide (a local PC controlling home media devices) and a remote guide (an external portable computer). In Sato, a remote user can access program listings via HTML pages and send commands over the Internet to the local PC to schedule recordings on a VTR. Petitioner contended that to the extent Sato did not explicitly teach that the remote guide's display is generated based on information received from the local guide, Humpleman supplied this missing element. Humpleman taught an improved home network where a local device generates and serves customized HTML program guide pages (e.g., filtered by user preference) to a remote, browser-equipped device for scheduling recordings.
    • Motivation to Combine: A POSITA would combine Humpleman’s teachings with Sato’s system for several reasons. The combination represented a simple application of a known technique (Humpleman's locally generated, customized remote guide) to improve a similar system (Sato's remote recording system). This would yield the predictable result of providing users with better access to desired content, a more complete picture of available programming on their local system, and a more efficient data transfer by customizing the guide information locally before transmission.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved integrating known web-based technologies (HTML pages served from a local device) into an existing web-based control system to enhance its functionality in a predictable manner.

Ground 2: Claims 1-54 are obvious over Woo in view of Mizuno.

  • Prior Art Relied Upon: Woo (Patent 5,485,219) and Mizuno (International Publication No. WO 97/18636).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Woo disclosed a system allowing users to schedule recordings on their local hardware from a remote location. However, Woo’s remote access was accomplished through a manual process where a user calls a human operator at a central control station, who then transmits a command to the user’s local hardware. Petitioner argued this manual system fulfilled the remote recording functionality but lacked an automated remote guide. Mizuno, in contrast, disclosed an automated system for controlling home devices (like VCRs) remotely over the Internet. Mizuno’s controller served HTML program guide pages to a remote user's computer, allowing the user to browse listings and select programs for recording on their local system, thereby automating the process taught manually in Woo.
    • Motivation to Combine: A POSITA would have been strongly motivated to replace Woo's antiquated and inconvenient manual call-in process with the automated, web-based remote guide taught by Mizuno. Automating a manual process was a well-established design principle at the time. This combination would predictably improve user control, obviate the expense and inefficiency of a human-operated call center, and provide a more user-friendly interface for scheduling recordings while away from home.
    • Expectation of Success: The expectation of success would be high, as it involved replacing a manual user input step with a known, automated web interface to achieve the same functional outcome—transmitting a recording instruction to local equipment.

4. Key Claim Construction Positions

  • "Local Guide": Petitioner argued that the broadest reasonable construction of "local guide" is a guide that generates a display of television program listings for use at the user premises. Critically, Petitioner adopted the Patent Owner's own broad construction from a parallel ITC Investigation, which posited that the "local guide" could be implemented on equipment that includes devices outside the user's home, such as a remote data server that provides guide information. This construction was central to Petitioner's argument that the prior art met this limitation, as references like Sato disclosed a local PC that received guide data from an external broadcast station, with the combination forming the "local guide."
  • "Guide" / "Electronic Program Guide": Petitioner proposed that these terms should be construed broadly as software operative to generate a display of television program listings. This construction was necessary to show that the HTML-based interfaces disclosed in the prior art (e.g., in Sato and Mizuno), which allow users to navigate listings and make selections, met the claim limitations for a "guide."