PTAB

IPR2017-01237

AT&T Services Inc v. Convergent Media Solutions LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Navigating Hypermedia
  • Brief Description: The ’840 patent describes systems and methods for using a computerized device (e.g., a PDA) to navigate a list of media content and control its presentation on either that same device or a separate media player device on a local network. The technology leverages network protocols like Universal Plug and Play (UPnP) for device discovery and control.

3. Grounds for Unpatentability

Ground 1: Obviousness over Elabbady, Palm, and Zintel - Claims 1-5, 16, 18-20, 24, 32, 34-35, 37-38, 44, 47, 51-53, 56, and 59-62 are obvious over the combination of Elabbady, Palm, and Zintel.

  • Prior Art Relied Upon: Elabbady (Patent 7,483,958), Palm (Application # 2001/0042107), and Zintel (Patent 6,910,068).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the core teachings of the challenged claims were present in the prior art. Elabbady taught a UPnP-based system where a client device (like a PDA) accesses a catalog of multimedia content and selects items for playback on networked players. Similarly, Palm described networked, UPnP-compliant media players (which could be handheld computers) that stream content after a user browses and selects it. Zintel provided a detailed technical foundation for UPnP, explaining the protocols for device discovery, description (learning device capabilities), and control. The combination allegedly disclosed all key limitations of independent claim 1: a portable device (the "second device," e.g., a PDA from Palm) uses a UPnP discovery protocol (from Zintel) to find media players (the "first device," e.g., a digital audio receiver from Elabbady) on a wireless network. The user browses a media list on the PDA and selects a content item, then chooses to play it either on the PDA itself or on the networked player by sending a resource indicator (a URL) to the selected device.
    • Motivation to Combine: A POSITA would combine these references because they addressed similar problems using complementary, UPnP-based solutions. Elabbady and Palm both described systems for networked media playback, making their combination natural. A POSITA implementing such a system would have been motivated to consult Zintel for its detailed teachings on the underlying UPnP framework that both Elabbady and Palm utilized. The combination offered the clear advantage of flexibility, allowing a user to employ a single portable device as both a media player and a remote control for other players on the network.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references. All three operated within the well-defined and standardized UPnP architecture, making the integration of a control point (Elabbady), a portable player (Palm), and the detailed UPnP protocols (Zintel) a matter of applying known principles to achieve a predictable result.

Ground 2: Obviousness over Elabbady, Palm, Zintel, and Katz - Claims 42, 54, and 55 are obvious over the combination of Elabbady, Palm, Zintel, and Katz.

  • Prior Art Relied Upon: Elabbady (Patent 7,483,958), Palm (Application # 2001/0042107), Zintel (Patent 6,910,068), and Katz (Patent 7,103,906).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the system established in Ground 1 by adding the teachings of Katz. Katz described media-on-demand systems where content could be converted or adapted to a format suitable for the specific client device requesting it. Petitioner argued this directly taught the limitations of the dependent claims. Specifically, Katz taught storing video in a global format like MPEG (mapping to claim 42) and using an intermediate server to convert it to a format compatible with the properties of the requesting device (e.g., a TV versus a handheld device). This enabled adapting a resource to differences between devices (mapping to claim 54) and mapping a resource served in one form to a corresponding, usable form for the player (mapping to claim 55).
    • Motivation to Combine: A POSITA would be motivated to incorporate Katz’s teachings into the Elabbady/Palm/Zintel system to create an improved and more efficient user experience. In a system with diverse playback devices (e.g., high-resolution TVs and low-resolution PDAs), ensuring that content is delivered in a device-appropriate format was a known design goal. Katz’s method of on-the-fly format conversion provided an obvious solution to avoid wasting bandwidth and to optimize playback quality for each specific device, making it a desirable feature to add to the base system.
    • Expectation of Success: Combining Katz’s teachings on format adaptation with the media delivery system of the primary references would have been straightforward. The concept of transcoding media for different client devices was a known technique, and integrating this server-side function into the established UPnP framework would have led to the predictable result of a more robust and versatile media system.

4. Key Claim Construction Positions

  • "the resource indicator comprises at least one of a URL, URI, and URN": Petitioner proposed this phrase should be construed to mean "the resource indicator includes at least one URL, URI, or URN." This construction, meaning the indicator is one of the listed identifiers (not all of them required simultaneously), was argued to be essential. Petitioner contended that this interpretation was supported by the patent's dependent claims, where claims 56, 57, and 58 each separately required the indicator to be a URL, URI, or URN, respectively, demonstrating they are alternatives.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-5, 16, 18-20, 24, 32, 34-35, 37-38, 42, 44, 47, 51-56, and 59-62 of the ’840 patent as unpatentable.