PTAB
IPR2018-01299
Sony Corp v. Realtime Adaptive Streaming LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2018-01299
- Patent #: 9,762,907
- Filed: June 28, 2018
- Petitioner(s): Sony Corporation and Polycom, Inc.
- Patent Owner(s): Realtime Adaptive Streaming LLC
- Challenged Claims: 1-14
2. Patent Overview
- Title: System and method for adaptive data compression
- Brief Description: The ’907 patent discloses a system for compressing video data by dynamically modifying compression system parameters based on the expected or anticipated throughput of a communications channel. The invention aims to balance compression speed with the resulting compression rate to optimize data transfer.
3. Grounds for Unpatentability
Ground 1: Claims 1-14 are obvious over Pauls in view of Brooks.
- Prior Art Relied Upon: Pauls (Patent 6,920,150) and Brooks (Patent 7,143,432).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Pauls taught a general framework for an adaptive communications system that selects from a plurality of compression (transcoding) techniques based on various factors, including the nature of the communications network and its available bandwidth. Pauls disclosed using well-known video compression algorithms like MPEG and H.263, which Petitioner asserted were asymmetric. However, Pauls did not provide extensive implementation details for adapting video compression to specific network conditions. Petitioner contended that Brooks filled this gap by teaching a real-time video compression system that is explicitly adaptive to the bandwidth of a communications channel. Brooks provided detailed examples of selecting different compression routines (e.g., MPEG-1 for a high-bandwidth DSL connection, MPEG-4 for a 56kbps modem connection) and adjusting parameters like resolution, color depth, and frame rate to match specific channel limitations. Petitioner mapped the limitations of claim 1 by arguing Pauls provided the processor-based system for analyzing network parameters and selecting from multiple compression algorithms, while Brooks provided the specific, known asymmetric routines and the explicit teaching of adapting them based on channel throughput for video data. The combination, Petitioner argued, taught all limitations of the independent claim, and the dependent claims were met by additional specific disclosures in the references (e.g., standardized algorithms, real-time compression, and analysis of video profile parameters).
- Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine the teachings of Brooks with Pauls to implement and improve Pauls’s adaptive compression system, particularly for video data. Pauls provided a general framework but lacked specific implementation details for video, whereas Brooks provided an explicit, detailed description of how to adapt various video compression routines based on channel bandwidth. A POSITA would have recognized that the specific techniques in Brooks were a natural and logical way to implement the broader concepts in Pauls, making the resulting system more robust, versatile, and capable of supporting a wider array of devices and network configurations.
- Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The combination involved applying the specific, known video compression techniques from Brooks to the established adaptive framework of Pauls. This was presented as a combination of prior art elements according to known methods to yield predictable results—namely, an improved and more capable adaptive video streaming system.
4. Key Claim Construction Positions
- "expected or anticipated throughput of a communications channel": Petitioner argued this term should be construed to include "bandwidth of a communications channel that is known a priori." This construction was asserted to be critical because it ensures claim 1 is not limited to systems that empirically measure throughput in real-time. Petitioner contended this broader scope is supported by the specification and is necessary to cover dependent claim 2, which explicitly recites that the throughput is "known apriori." This construction allows prior art like Brooks, which teaches selecting compression based on the known, typical bandwidth of different network types (e.g., DSL, modem, wireless), to be applied to the claims.
5. Relief Requested
- Petitioner requested institution of an inter partes review and cancellation of claims 1-14 of the ’907 patent as unpatentable.
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