PTAB

IPR2018-01497

Amazon.com Inc v. CustomPlay LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and methods for providing information associated with a video.
  • Brief Description: The ’950 patent discloses systems for providing supplemental information to a viewer about items depicted in a video. The invention purports to solve the problem of a user not acting quickly enough to request information by contemporaneously displaying indications for items in the current video frame as well as indications for items from recently passed frames.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rangan, Rakib, and Abecassis - Claims 2, 4, 6, 14, 16, and 19 are obvious over combinations of Rangan, Rakib, and Abecassis.

  • Prior Art Relied Upon: Rangan (Patent 6,154,771), Rakib (Application # 2009/0327894), and Abecassis (Patent 6,038,367).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rangan, by itself, renders independent claims 6 and 19 obvious. Rangan disclosed a system to overcome user delay in selecting hyperlinks in a video by displaying "thumbnail images" of past keyframes, complete with their interactive "hotspots" (the initial indications), alongside the current video playback. As new scenes appeared, new thumbnails with new hotspots (the subsequent indications) were added to a storyboard display. This resulted in the contemporaneous display of indications for past play locations and subsequent play locations, directly teaching the core limitation of the independent claims. Rangan’s system retrieved frame identifiers (keyframes or frame numbers) and displayed responsive indications (hotspots) for both past and current scenes simultaneously.
    • Motivation to Combine: For dependent claims, Petitioner argued a POSITA would combine Rangan with Rakib and Abecassis. To add the limitations of claim 2 (requesting and displaying additional information), a POSITA would look to Rakib, which explicitly taught a hierarchical information system where a user could make an initial request and then request further details. This was a predictable improvement to Rangan's system to enhance user experience. To add the limitations of claim 4 (pausing and resuming playback), a POSITA would incorporate the teachings of Rangan (which suggested optional pausing) and Abecassis (which taught resuming from the beginning of a video clip). This combination was presented as a simple application of known techniques to achieve predictable results, such as preventing a user from missing the primary video content.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because all references were in the field of interactive video and addressed the same problems. Combining known features like requesting additional information (Rakib) or specific pause/resume functionality (Abecassis) with Rangan's base system involved applying conventional techniques to a known system.

Ground 2: Obviousness over Armstrong and Livesey - Claims 2, 6, 14, 16, and 19 are obvious over Armstrong in view of Livesey.

  • Prior Art Relied Upon: Armstrong (Application # 2007/0003223) and Livesey (Application # 2008/0253739).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended Armstrong taught most limitations of the independent claims. Armstrong disclosed a system where a menu of items (initial indications) corresponding to a specific video frame could be displayed. Crucially, Armstrong taught that as new items are introduced in subsequent frames, indices for them can be "added" to the existing menu. Petitioner argued this "adding" of new indices (subsequent indications) while retaining old ones constituted the contemporaneous display required by the claims. Armstrong retrieved frame numbers to determine which menu to display and which new indices to add, mapping directly to the "retrieving a subsequent video frame identifier" limitation.
    • Motivation to Combine: To the extent Armstrong was viewed as only displaying indices for items currently on-screen, Petitioner argued a POSITA would combine it with Livesey. Livesey explicitly taught maintaining a visual indication (e.g., an icon) on screen "until the end of a current scene," even after the associated object was no longer visible, to give the user more time to select it. A POSITA would be motivated to modify Armstrong's menu to persist throughout a scene, as taught by Livesey, to solve the well-known problem of user reaction delay and to prevent distracting flickering of menu items. This combination represented the simple substitution of one known method of displaying indications (Livesey's persistent icon) for another (Armstrong's frame-specific menu) to achieve the predictable benefit of an improved user experience.
    • Expectation of Success: Both references were directed to providing supplemental information for videos. Petitioner argued that implementing Livesey's extended display time for the indices in Armstrong's system was a straightforward modification with a high expectation of success.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against all claims based on the combination of Rakib and Livesey, which relied on similar motivations to combine to solve the problem of user delay in interactive video systems.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 2, 4, 6, 14, 16, and 19 of the ’950 patent as unpatentable.