PTAB

IPR2018-01413

Sony Corp v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Adaptive Data Compression Based on Channel Throughput
  • Brief Description: The ’477 patent discloses a system for dynamically compressing video data based on the measured throughput of a communications channel. The system selects from a plurality of different compression encoders to balance compression speed and the resulting compression ratio, thereby optimizing data transmission over networks with varying bandwidth.

3. Grounds for Unpatentability

Ground 1: Claims 1-29 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 the combination of Pauls and Brooks taught all limitations of the challenged claims. Pauls disclosed a general framework for adaptive data transmission, wherein a system selects from a plurality of transcoding techniques (including standardized video compression algorithms like MPEG and H.263) based on various factors, including the "nature of the communications network" such as "available bandwidth." Pauls taught adapting compression for different data types and network conditions (e.g., wired vs. wireless) to improve data transfer performance.

    Brooks was argued to provide the specific implementation details for the adaptive system taught by Pauls, particularly for video data. Brooks taught a real-time video transcoding system that adapts simultaneous output video streams based on the specific "bandwidth limitations" and channel conditions of various client devices. It provided explicit examples of selecting different compression encoders and formats (e.g., MPEG-1 for a high-bandwidth DSL connection, MPEG-4 for a mid-bandwidth modem connection) to match the available channel capacity.

    Together, Petitioner asserted that Pauls provided the claimed plurality of different asymmetric encoders and a processor for selecting among them, while Brooks provided the explicit teaching of determining channel bandwidth in bits per second and selecting a specific encoder to compress video data according to those determined bandwidth limitations. For dependent claims, Petitioner argued the combination taught using standardized algorithms (Pauls), determining parameters like resolution (Brooks), and performing compression in real-time over a distributed network like the Internet (Pauls and Brooks).

    • Motivation to Combine (for §103 grounds): Petitioner contended a person of ordinary skill in the art (POSITA) would combine the teachings of Pauls and Brooks to improve the functionality of the Pauls system. A POSITA would have recognized that the detailed, practical methods in Brooks for adapting video compression to specific network bandwidths provided a clear and advantageous way to implement the more general adaptive framework of Pauls. The combination would yield the predictable result of a more robust and versatile compression system capable of operating effectively across the diverse network connections and devices described in Brooks.

    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because combining the references involved applying known video compression techniques to solve the known problem of optimizing data transmission over variable-bandwidth networks. Brooks' teachings were presented as a natural extension of the concepts in Pauls, providing specific solutions that would predictably enhance the primary system's performance without undue experimentation.

4. Key Claim Construction Positions

  • "throughput of a communications channel": Petitioner proposed this term should be interpreted to include "bandwidth of a communications channel."
    • Rationale: This construction was asserted to be necessary for applying the prior art. Petitioner argued the ’477 patent’s specification consistently equates the terms, for example, by using the phrase "actual or expected throughput (bandwidth)" and describing the invention as providing "bandwidth sensitive" data compression. Since the prior art, particularly Brooks, explicitly discussed adapting compression based on "bandwidth," this construction was central to the obviousness argument.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-29 of Patent 9,769,477 as unpatentable.