PTAB

IPR2018-01758

Unified Patents Inc v. MOAEC Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Music Organizer and Entertainment Center
  • Brief Description: The ’539 patent is directed to a music organizer system that allows users to access and store music from networks. The system provides a graphical user interface (GUI) for searching a music collection using various categories and creating playlists for customized playback.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nathan in view of Iki - Claims 1-6, 9, 15-16, 19, 21, and 24 are obvious over Nathan in view of Iki.

  • Prior Art Relied Upon: Nathan (Patent 6,182,126) and Iki (Patent 6,816,172).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nathan, which discloses a "digital home audiovisual information recording and playback apparatus," teaches nearly all limitations of the challenged claims. Nathan’s system allows users to download a "catalog of musical titles" from a server, search for songs using categories (e.g., rock, dance, jazz), and create a playback queue. Petitioner asserted that Nathan fails to expressly disclose the "ownership category flag," which indicates whether a music selection is currently resident on the user's local storage device. To supply this element, Petitioner relied on Iki, which teaches a multimedia entertainment system that determines and presents the location of data corresponding to a selection. Petitioner contended that Iki’s disclosure of tracking whether data is stored locally versus remotely teaches the claimed ownership flag.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Nathan and Iki to enhance the user experience of Nathan’s resource-constrained device. By incorporating Iki’s teaching of location identification, a POSA would provide users with the valuable information of whether a desired music selection is stored locally (and thus accessible offline) or must be downloaded or streamed, which was a known design need for such systems.
    • Expectation of Success: A POSA would have a reasonable expectation of success in this combination. The modification would involve adding a location data field to Nathan’s existing "catalog of musical titles," which Petitioner characterized as a minor and predictable update to a database structure.

Ground 2: Obviousness over Leeke in view of Corwin - Claims 1-6, 14-16, 19, 21, and 24 are obvious over Leeke in view of Corwin.

  • Prior Art Relied Upon: Leeke (Patent 6,587,127) and Corwin (Patent 5,808,225).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Leeke discloses a system for collecting, personalizing, and playing music from various network sources, teaching most of the claimed features. Leeke’s system supports categorical searches, playlist creation, and provides indicators (e.g., a "streaming indicator") that inform the user of the music's location (local vs. remote), thereby teaching the "ownership category flag." While Leeke implies the use of compressed music through its compatibility with RealPlayer, Petitioner argued it does not expressly teach data compression. Corwin was introduced to supply this teaching, as it explicitly discloses methods for compressing audio music signals to address limited storage capacity and network bandwidth—problems also recognized by Leeke.
    • Motivation to Combine: A POSA would combine Leeke and Corwin to address the well-understood problems of bandwidth and storage constraints in transmitting and storing digital music. Since Leeke’s system was designed to handle various data formats, a POSA would be motivated to integrate Corwin’s explicit and improved compression techniques to provide higher quality music over low-bandwidth connections and reduce storage requirements on the user's device.
    • Expectation of Success: A POSA would have a reasonable expectation of success because Leeke’s system was already modular and capable of handling compressed data formats like RealPlayer. Therefore, adapting it to use the compressed audio formats taught by Corwin would be a straightforward modification within the skill of a POSA.

4. Key Claim Construction Positions

  • "category flag": Petitioner proposed this term be construed to mean "indicators of one or more categories," based on its plain and ordinary meaning and supporting language in the ’539 patent specification.
  • "ownership category flag": This term was central to the petition. Petitioner argued, based on the patent’s reexamination history, that the term should be narrowly construed to mean "an indicator that a music selection is currently resident in a storage device of the music organizer and entertainment center." Petitioner asserted this construction distinguishes it from a broader concept of legal ownership or purchase status and aligns it with the feature that the Examiner found allowable during reexamination. This construction was critical for mapping Iki’s "location" data and Leeke’s "streaming indicator" to the claim limitation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was not warranted because the primary prior art references asserted in the petition (Nathan, Iki, Leeke, and Corwin) were not considered during the original prosecution of the ’539 patent or during its subsequent reexamination.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-6, 9, 14-16, 19, 21, and 24 of the ’539 patent as unpatentable.