PTAB

IPR2018-01001

AlARmCom Inc v. Rothschild Broadcast DisTributIONs Systems LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System, Method and Device for Media Content Storage and Delivery
  • Brief Description: The ’221 patent discloses systems and methods for on-demand media content storage and delivery. The system uses a hierarchical server architecture, including remote servers and broadcast servers, to manage content requests from consumer devices and allegedly tailor costs based on consumer needs and requested content.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4-8, and 10-13 are obvious over Hardin in view of Monroe.

  • Prior Art Relied Upon: Hardin (Application # 2008/0155059) and Monroe (Patent 7,684,673).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hardin discloses the core elements of independent claims 1 and 7. Hardin teaches a hierarchical system for on-demand media delivery with higher-level national servers and lower-level regional servers. Petitioner mapped Hardin’s regional servers to the claimed "first server" and the national servers to the "second server" (recited in dependent claim 6). Hardin’s system receives a request from a consumer device, determines if the content is locally available (a "content request"), and if not, retrieves it from the national server for storage at the regional server (a "storage request"). Hardin also discloses verifying a registered user, checking content availability, and identifying restrictions like parental controls.
    • Motivation to Combine (for §103 grounds): Petitioner asserted that while Hardin teaches renting content for a "rental period," it does not explicitly disclose that the user’s request message includes data specifying the length of that period. Monroe was introduced to supply this missing element, as it expressly teaches that a user can set preferences for how long a program is kept in shared storage ("kept only for a certain amount of days"). A person of ordinary skill in the art (POSITA) would combine Monroe’s specific time-storage feature with Hardin’s system to better manage and minimize the storage of unnecessary content on regional servers, which directly furthers Hardin's stated goal of supporting a vast library of titles without overburdening local storage.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because Hardin already discloses a web browser interface for user selections. Modifying this interface to include an option for specifying a storage duration, as taught by Monroe, would be a trivial exercise for a software programmer.

Ground 2: Claims 3 and 9 are obvious over Hardin in view of Monroe and Remijn.

  • Prior Art Relied Upon: Hardin (Application # 2008/0155059), Monroe (Patent 7,684,673), and Remijn (WO 2007/060016).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Hardin and Monroe from Ground 1 and adds Remijn to address the limitations of dependent claims 3 and 9. These claims require that if a consumer device identifier does not correspond to a registered device, the system sends a registration message to prompt registration. Petitioner argued that Remijn explicitly teaches this functionality. Remijn discloses a system for authenticating mobile devices where, if a device is unregistered, a provisioning server automatically prompts registration before the device can access online services.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate Remijn’s teaching to enhance the Hardin/Monroe system. Since Hardin already performs a verification step for registered users, adding a process to handle unregistered users by prompting them to register is a logical and predictable improvement. This would provide a complete and user-friendly authentication workflow, which was a well-known objective in the art. The teachings of Remijn, though focused on mobile devices, would be readily applicable by a POSITA to other consumer devices like the set-top boxes and web portals used in Hardin's system.
    • Expectation of Success (for §103 grounds): A POSITA would have expected success in this combination because prompting an unregistered device to register is a simple extension of the verification process already disclosed in Hardin.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-13 of the ’221 patent as unpatentable.