PTAB

IPR2017-01692

Sony Corp v. ARRIS Solutions Inc

Key Events

Petition

petition

Title: Method and Apparatus for Implementing Seamless Playback of Continuous Media Feeds
Brief Description: The ’147 patent discloses a method for managing a continuous video feed by storing it as a series of smaller, discrete content files rather than a single large circular buffer. The system sequentially creates new files, and once a predetermined amount of video is stored (i.e., a certain number of files exist), it deletes the oldest file to free up disk space for new content.

Prior Art Relied Upon: Kraft (International Publication No. WO 96/27864).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kraft, which discloses a computer-based event capturing system, teaches every element of the challenged independent claims. Kraft's system continuously records video images into a series of files of a predefined length (e.g., t seconds). When a current file reaches its defined length (the "predetermined condition"), it is closed and a new file is created. Kraft explicitly discloses that once a maximum number of files (n) is stored, "the oldest file is deleted and the newest file is stored in a new location." Petitioner asserted this directly maps to the limitations of creating a series of files from a continuous feed and deleting the oldest file when a predetermined amount of feed is stored. The argument extends to dependent claims, alleging Kraft also discloses tagging files with information (claim 6/16) and defining the file-creation condition based on file size (claim 5/15).

Prior Art Relied Upon: Kraft (WO 96/27864) and Cobbley (Patent 5,614,940).
Core Argument for this Ground:
- Prior Art Mapping: This ground was presented as an alternative in case Kraft was found not to explicitly teach the "encoding" limitation of claim 1. Petitioner contended that Kraft teaches all other method steps, including storing a continuous video feed in a series of files and deleting the oldest file. Cobbley explicitly taught a method for storing broadcast information that involved receiving a continuous stream and using a "capture device" to convert and compress the video data (e.g., into MPEG format) for efficient storage.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to modify Kraft’s system by incorporating the video compression techniques from Cobbley. The motivation was to increase storage efficiency, a well-known goal in the field. Compressing the video stream before storage, as taught by Cobbley, would allow the system in Kraft to store more video content within the same fixed number of files, a clear and desirable improvement.
- Expectation of Success: A POSITA would have had a reasonable expectation of success because applying a standard, well-known compression algorithm (like MPEG from Cobbley) to a digital video stream (as in Kraft) was a routine and predictable task. The combination involved applying a known technique to a known system to achieve a predictable result.

Prior Art Relied Upon: Kraft (WO 96/27864) and Cobbley (Patent 5,614,940).
Core Argument for this Ground:
- Prior Art Mapping: This ground addressed dependent claims requiring delayed deletion of content. While Kraft taught the underlying system of deleting the oldest file, Cobbley explicitly taught the features of the challenged dependent claims. Cobbley disclosed a "cache manager" that "allows end user A to finish watching the older version of the segment while storing the newer version." It further taught delaying deletion until "no end users are viewing one of the older versions" and preventing new readers from accessing old segments that are about to be deleted.
- Motivation to Combine: A POSITA would have been motivated to add Cobbley’s user-aware deletion logic to Kraft's system to solve a known problem: preventing content from being deleted while a user is actively watching it. This modification would provide a significant improvement to the user experience, which is a strong motivation for combination.
- Expectation of Success: Implementing a check to determine if a file is currently being accessed before executing a deletion command was a standard and well-understood programming technique. A POSITA would have readily known how to integrate this logic from Cobbley into the software controlling Kraft's file management system with a high expectation of success.

Petitioner proposed a construction for the phrase "establishing a new file as said current file" (recited in claims 1, 5, 11, and 15).
Proposed Construction: "creating and opening a new file to which the current digital data stream is stored."
Relevance: Petitioner argued this construction aligns with the plain meaning derived from the ’147 patent’s specification and figures. This interpretation was crucial because Petitioner contended that Kraft explicitly disclosed this step in its flowchart, which showed a process where a new file is "opened" and the system "begins recording images and storing the images in the new file."

Petitioner requested the institution of an inter partes review and the cancellation of claims 1-6, 11-16, 19, and 20 of the ’147 patent as unpatentable.