PTAB

IPR2018-01413

Sony Corporation v. Realtime Adaptive Streaming LLC

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1. Case Identification

2. Patent Overview

  • Title: System and Method for High-Performance, Real-Time Data Compression
  • Brief Description: The ’477 patent describes systems for dynamically compressing and decompressing data by selecting from multiple available compression encoders and algorithms. The selection is based on monitored system parameters, primarily the throughput (or bandwidth) of a communication channel, to balance compression speed and ratio.

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 disclosed all limitations of the challenged claims. Pauls was presented as teaching a general framework for adaptive data compression, where a system selects among various transcoding techniques (including different compression encoders like MPEG and H.263) based on factors including the nature of the communications network, such as its "available bandwidth" and "bit rate." Pauls’s system adaptively formats data to improve transmission performance, particularly for connections with limited bandwidth like wireless networks. However, Pauls provided limited implementation details for video.

      Brooks was asserted to supply these missing details. Brooks teaches a real-time video formatting system that is explicitly adaptive to the "bandwidth limitations" and "channel conditions" of the network connecting to a client device. It provides concrete examples of selecting different compression formats (e.g., MPEG-1 for a high-bandwidth DSL connection, MPEG-4 for a mid-bandwidth modem connection) and further customizing the output by adjusting parameters like color depth, resolution, and frame rate to match the available bandwidth.

      Petitioner mapped these teachings to independent claim 1 by arguing that Pauls taught a system with a processor and a plurality of asymmetric encoders that are selected based on network parameters. Brooks was argued to provide the explicit teaching of determining specific channel bandwidths (throughput) and using that information to select and configure an appropriate encoder to adapt the video stream, thereby rendering the full scope of the claim obvious. Arguments for dependent claims followed similar logic, leveraging specific disclosures in the references, such as Brooks's teaching of adjusting resolution (claim 7) and data rates (claim 8), and Pauls's disclosure of standardized algorithms like H.263 (claim 6).

    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine the teachings of Pauls and Brooks to achieve a predictable improvement. A POSITA implementing the adaptive compression system of Pauls would have looked to contemporary art like Brooks for specific, well-known techniques to handle video data across various network conditions. Brooks provided an explicit roadmap for adapting compression based on bandwidth, which would have been a natural and obvious way to enhance the more general system of Pauls to make it more robust and versatile for video streaming applications.

    • Expectation of Success: The combination would have yielded predictable results. Pauls established the goal of adapting compression to network characteristics, and Brooks provided known, successful methods for achieving that goal with video. Combining these teachings was presented as applying known techniques to a known system to improve its functionality, which a POSITA would have undertaken with a high expectation of success.

4. Key Claim Construction Positions

  • Petitioner argued that the claim term "throughput of a communications channel" should be interpreted to include "bandwidth of a communications channel."
  • This construction was asserted to be critical because the prior art, particularly Brooks, frequently uses the term "bandwidth" when describing the network characteristic used to adapt the video compression. Petitioner supported this position by pointing to the ’477 patent specification, which allegedly uses the terms interchangeably, for instance by repeatedly referring to "throughput (bandwidth)" and describing the invention as providing "bandwidth sensitive" data compression.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-29 of the ’477 patent as unpatentable under 35 U.S.C. §103.