PTAB

IPR2018-00864

Hulu LLC v. Sound View Innovations LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Caching Streaming Multimedia on the Internet
  • Brief Description: The ’074 patent describes cache replacement techniques for streaming multimedia (SM) objects in a network. The system uses "helper servers" that cache SM objects, which are segmented into smaller units ("chunks"), to reduce server load and improve latency for clients. The alleged novelty relates to a replacement policy that preferentially retains the beginning portions of cached SM objects to reduce start-up latency for subsequent users.

3. Grounds for Unpatentability

Ground 1: Claims 3, 5, and 9 are obvious over Wolf in view of Aggarwal.

  • Prior Art Relied Upon: Wolf (Patent 6,463,508) and Aggarwal (Patent 5,924,116).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wolf disclosed the core elements of the ’074 patent’s method. Wolf described a networked environment with proxy servers (analogous to helper servers) that cache media streams to facilitate delivery from a content server to clients. Wolf’s media objects were divided into time-ordered "segments" (analogous to the claimed "chunks"), and its cache replacement process used a least-recently-used (LRU) stack to identify and discard segments from the least popular objects to free up space. However, Wolf discarded segments sequentially. Petitioner contended that Aggarwal, which taught a cache replacement method, supplied the missing element of first "composing a set" of candidate objects for deletion to ensure the required amount of space would be freed before any data was actually purged.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Wolf and Aggarwal to improve the efficiency and predictability of Wolf's cache replacement routine. Aggarwal's method of first identifying a complete set of objects/segments to be deleted before taking action avoids the inefficient scenario in Wolf where segments might be discarded only to find that not enough space can be freed for the new object. This modification represented a known solution to improve a known system.
    • Expectation of Success: A POSITA would have had a high expectation of success. The combination involved applying a known cache management optimization (set creation from Aggarwal) to a standard segmented media caching system (Wolf), which was a predictable integration of complementary technologies.

Ground 2: Claim 3 is obvious over Ueno in view of Dan and Aggarwal.

  • Prior Art Relied Upon: Ueno (Patent 5,991,811), Dan (Patent 5,787,472), and Aggarwal (Patent 5,924,116).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Ueno disclosed a video-on-demand system with a center server, local servers (helper servers), and clients. Ueno’s video sources were divided into time-ordered segments for caching and were erased based on metrics including last access time and position within the video (deleting tail-end segments first). Petitioner argued Dan supplemented Ueno by teaching the common practice of further dividing larger data segments into discrete, fixed-size blocks to correspond with the cache disk's fundamental storage units for more efficient memory allocation. As in Ground 1, Aggarwal was cited for its teaching of creating a set of objects for replacement before purging the cache.
    • Motivation to Combine: A POSITA would combine Ueno and Dan to optimize storage utilization, as dividing Ueno's video segments into Dan's smaller, standardized blocks was a known and beneficial implementation detail. A POSITA would further incorporate Aggarwal's set creation method into the Ueno/Dan system for the same reasons articulated in Ground 1: to improve the cache replacement process by pre-calculating the segments to be erased. This would prevent the unnecessary deletion of valuable cached data if sufficient space could not ultimately be made available.
    • Expectation of Success: The combination would have been straightforward with a high expectation of success. Modifying Ueno's segments to be stored as Dan's blocks was a conventional storage optimization. Applying Aggarwal's logic to Ueno's replacement algorithm was a trivial change that would predictably enhance its efficiency.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 9 based on the combination of Ueno and Aggarwal, relying on similar design modification theories and motivations as those presented for claim 3 in Ground 2.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 3, 5, and 9 of the ’074 patent as unpatentable under 35 U.S.C. §103.