PTAB

IPR2017-02064

Sony Corp v. ARRIS Enterprises LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Communication Management System and Method
  • Brief Description: The ’502 patent discloses a broadband multimedia system for managing and routing data from media sources to network transmitters. The system uses a session manager that provides routing instructions to a router based on policy information retrieved from a policy database.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bigham - Claims 1-4, 6, 13-14, 16, 18-19, 21, 23-25, 27, 29-30, 32, 34-35, and 37 are obvious over Bigham.

  • Prior Art Relied Upon: Bigham (Patent 5,544,161).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bigham, which describes a digital broadband multimedia system, disclosed all limitations of the challenged independent claims. Bigham’s ATM packet demultiplexer (explicitly called an "MPEG packet router") was asserted to be the claimed "router." The "video manager" in Bigham was identified as the claimed "session manager" that provides routing instructions. Finally, Bigham's "level 1 gateway controller" was argued to be the claimed "policy database" that provides policy information (e.g., bandwidth requirements, user access controls) to the session manager to control routing. Petitioner contended that dependent claims reciting features like QAM units (Bigham's RF digital modulators) and HFC networks were also taught by Bigham.
    • Motivation to Combine (for §103 grounds): Although a single-reference ground, Petitioner argued that a person of ordinary skill in the art (POSITA) would have been motivated to combine the policy storage capabilities of the gateway shown in Bigham's Figure 2 system with the gateway of Bigham's Figure 1 system. This combination was presented as a simple and desirable modification to provide subscribers with more control over broadcast services, such as access restrictions and pay-per-view ordering, which Bigham suggested was a known need in the art.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining features from different embodiments within Bigham, as they were directed to solving similar problems in broadband network management.

Ground 2: Obviousness over Coddington - Claims 1-4, 6-7, 18-19, 21-22, 29, 30, 32-35, and 37-38 are anticipated and/or obvious over Coddington.

  • Prior Art Relied Upon: Coddington (Patent 5,410,343).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Coddington disclosed a network architecture for transmitting television programming that met all limitations of the independent claims. Coddington's digital cross-connect switch (DCS) was identified as the claimed "router," as it routes video signals according to routing data. The combination of Coddington’s "network management system" and "video gateway" was argued to function as the claimed "session manager," which establishes and monitors connections and provides routing data to the DCS. The video gateway, which stores subscriber access data and order information, was mapped to the claimed "policy database." Petitioner argued Coddington further disclosed various network types recited in dependent claims, including DSL (using ADSL devices) and wired networks (coaxial cables, optical fibers).
    • Key Aspects: For limitations requiring a single, shared "communication bus," Petitioner argued that while Coddington shows logical connections, a POSITA would have been motivated to implement these connections as a single shared bus for reasons of cost and efficiency, as this was a common and well-known design choice.

Ground 3: Obviousness over Bigham in view of Gupta - Claims 5, 7, 15, 17, 20, 22, 26, 28, 31, 33, 36, and 38 are obvious over Bigham in view of Gupta.

  • Prior Art Relied Upon: Bigham (Patent 5,544,161) and Gupta (WO 97/44986).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claims reciting a "satellite network" or a "wireless network." Petitioner argued that while Bigham taught the core system, Gupta supplied the teaching of using a satellite network for broadband content delivery.
    • Motivation to Combine: A POSITA would combine Bigham with Gupta to improve Bigham’s system to support a larger number of subscribers. Petitioner noted that Bigham’s Optical Network Units (ONUs) serve a small number of subscribers, whereas Gupta’s Satellite Remote Nodes (SRNs) could serve significantly more (e.g., 500). A POSITA would have been motivated to replace Bigham's ONUs with Gupta's SRNs to increase subscriber capacity and network efficiency, a need explicitly identified in Bigham.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references disclose similar broadband multimedia systems and address the common goal of cost-effective content delivery to subscribers.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge based on the combination of Coddington and Gupta to teach claims reciting a satellite network, relying on a similar motivation to transmit disclosed satellite content and support an increased number of subscribers.

4. Key Claim Construction Positions

  • "Router": Petitioner argued that "router" should be construed broadly as "a component that directs data according to received routing information." This construction was based on the term's plain meaning and the patent's specification. Petitioner explicitly argued against importing limitations from a preferred embodiment (e.g., a "complex routing situation" described in relation to Figure 6 of the patent), contending that such a narrow construction would be improper. This broader construction was critical to mapping the term onto the "ATM packet demultiplexer" of Bigham and the "digital cross-connect switch" of Coddington.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 and 13-38 of the ’502 patent as unpatentable under 35 U.S.C. §§ 102 and/or 103.