PTAB

IPR2019-00281

Comcast Cable Communications LLC v. Rovi Guides Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Providing a Transport Control Interface
  • Brief Description: The ’956 patent discloses an interactive television application that provides a transport control interface, such as a progress bar, for viewing and recording television content. The core alleged invention is a graphical interface that visually distinguishes between a user-initiated recording (a "first stored time segment") and content that is automatically recorded into a buffer memory (a "second stored time segment").

3. Grounds for Unpatentability

Ground 1: Obviousness over Son, Jung, and Logan (Claims 1, 2, 4-6, 11, 12, 14-16)

  • Prior Art Relied Upon: Son (Application # 2003/0067886), Jung (IEEE Transactions, Nov. 2001), and Logan (Patent 5,371,551).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Son, a personal video recorder (PVR) system, taught nearly all limitations of the independent claims. Son’s on-screen “guide bar” serves as the claimed “transport control interface” and uses different colors to visually distinguish user-selected “clipping regions” (the first stored segment) from other buffered program segments. However, Son’s buffering is user-initiated. Petitioner asserted that Jung and Logan remedy this deficiency by teaching the "automatic" recording of a program into buffer memory. Jung’s PVR system “always and automatically stores TV programs to HDD,” and Logan discloses a system that “continuously” stores a broadcast program into a buffer memory without user attention. Furthermore, Jung’s interface displays program-specific start and end times, satisfying the “time length” limitation.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to improve Son’s system. Replacing Son’s user-initiated buffering with the automatic, continuous buffering taught by Jung and Logan was argued to be a predictable solution to prevent user error and avoid missing program content. This modification would expand the amount of buffered content available for time-shifting functions. Adding Jung’s display of program-specific start/end times would provide more useful information to the user than Son’s display of absolute time.
    • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success because all references relate to analogous PVR systems with similar components (processors, storage, user interfaces). The combination would primarily involve a predictable software modification to automate a previously manual process (buffering), a well-known design choice at the time.

Ground 2: Obviousness over Son-Jung-Logan in view of Horowitz (Claims 3 and 13)

  • Prior Art Relied Upon: Son (Application # 2003/0067886), Jung (IEEE Transactions, Nov. 2001), Logan (Patent 5,371,551), and Horowitz (Application # 2004/0078817).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the primary combination to address dependent claims 3 and 13, which require “receiving a change in running time of the video program” and “modifying the transport control interface” to reflect that change. Petitioner contended that Horowitz explicitly taught this functionality. Horowitz described a video recording system with an electronic program guide (EPG) that receives real-time updates to broadcast schedules and modifies the on-screen guide to display updated program start and end times.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Horowitz’s teachings into the Son-Jung-Logan system to improve recording accuracy. The benefit of accurately recording programs when broadcast schedules change is a compelling reason to add this known feature. The modified system would provide the user with more accurate program information and enhanced recording flexibility, a clear advantage.
    • Expectation of Success: Success was expected because Horowitz taught a comparable system and the integration would involve a straightforward software modification to process EPG update data, which the base Son system already handled.

Ground 3: Obviousness over Son-Jung-Logan in view of Tomita (Claims 7-10 and 17-20)

  • Prior Art Relied Upon: Son (Application # 2003/0067886), Jung (IEEE Transactions, Nov. 2001), Logan (Patent 5,371,551), and Tomita (Application # 2003/0142956).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the simultaneous display of a second video program and either integrating information from both programs into a single interface or generating a second, separate interface. Petitioner argued that while the primary combination did not teach this, Tomita disclosed a recording apparatus that simultaneously displays two videos (e.g., a live recording and a playback) in a picture-in-picture format. Tomita further taught displaying separate status bars for each video stream or integrating position information for both into a single status bar.
    • Motivation to Combine: A POSITA would combine Tomita’s teachings to improve the base system by adding the well-known and desirable feature of picture-in-picture capability. This would allow a user to monitor one program while viewing another, enhancing the user experience. The combination was presented as the application of a known technique (simultaneous display) to a similar device (a PVR) to yield predictable results.
    • Expectation of Success: Success was expected due to the technical overlap between the systems. Modifying the Son-Jung-Logan system to display two video streams from its buffer was a foreseeable software update.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Safadi (Application # 2001/0051037), which taught the use of two tuners to simultaneously record and watch programs from different sources.

4. Key Claim Construction Positions

  • "buffer memory": Petitioner argued for the construction “device or storage area used to store data temporarily.” This broad construction was supported by the patent’s specification and extrinsic evidence, and crucially encompasses storage like Hard Disk Drives (HDDs), as used in the prior art, not just more volatile memory like RAM.
  • "time length": Petitioner proposed construing this term as “duration of time,” consistent with the Patent Owner’s position in a related ITC action. This construction is broad enough to include both quantitative (e.g., 120 minutes) and qualitative (e.g., a progress bar showing start and end times) indications of a program's duration, as taught by the prior art.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of the ’956 patent as unpatentable.