PTAB

IPR2019-00283

Comcast Cable Communications, LLC v. Rovi Guides, Inc.

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1. Case Identification

2. Patent Overview

  • Title: SYSTEMS AND METHODS FOR PROVIDING A TRANSPORT CONTROL INTERFACE
  • Brief Description: The ’956 patent describes an interactive television application that provides a transport control interface (e.g., a progress bar) when television content is recorded or viewed. The system uses control circuitry and an interactive program guide to display information about video programming, including visually distinguishing between different segments of a stored program.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-2, 4-6, 11-12, and 14-16 over Kaminski and Son

  • Prior Art Relied Upon: Kaminski (Application # 2003/0121055) and Son (Application # 2003/0067886).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kaminski taught a video recording system with a graphical user interface (GUI) featuring a progress bar that indicates program length and visually distinguishes between automatically buffered segments and other segments. However, Petitioner contended Kaminski did not explicitly disclose an interface that simultaneously displays and visually distinguishes between a user-command recorded segment and an automatically buffered segment of the same program. Son was argued to supply this missing element by teaching a "clipping" function that allows a user to select a portion of a buffered ("time-shifted") program for permanent recording. Son's guide bar then visually distinguishes this user-selected "clipped" region from the rest of the buffered content.
    • Motivation to Combine: A POSITA would combine Son’s clipping feature with Kaminski’s system to provide users with greater recording flexibility and to conserve storage space. Son's teachings were presented as a known solution to a recognized drawback in systems like Kaminski's, which only allowed for recording the entire buffered segment.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success, as the combination involved applying a known software-based feature (clipping) from Son to a similar PVR system (Kaminski) to achieve the predictable result of more efficient recording.

Ground 2: Obviousness of Claims 3 and 13 over Kaminski, Son, and Safadi

  • Prior Art Relied Upon: Kaminski (Application # 2003/0121055), Son (Application # 2003/0067886), and Safadi (Application # 2001/0051037).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Kaminski-Son combination to address claims 3 and 13, which require "receiving a change in running time of the video program" and modifying the interface accordingly. Petitioner argued that Safadi taught a PVR system that addresses the unpredictability of program start and end times by using electronic program guide (EPG) data to determine updated times and ensure accurate recording despite schedule changes.
    • Motivation to Combine: A POSITA would be motivated to add Safadi's functionality to the Kaminski-Son system to improve its recording accuracy. This modification would address the well-known problem of television program schedule overruns by incorporating a known solution, thereby providing more accurate timing information and enhancing recording flexibility.

Ground 3: Obviousness of Claims 7-10 and 17-20 over Kaminski, Son, and Tomita

  • Prior Art Relied Upon: Kaminski (Application # 2003/0121055), Son (Application # 2003/0067886), 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 transport control interface or generating a second, separate interface. Petitioner asserted that Tomita taught a system that could simultaneously display two video streams (e.g., in a picture-in-picture format) from different parts of a storage medium. Tomita further disclosed integrating position information for both streams into a single status bar or, alternatively, displaying two separate status bars.
    • Motivation to Combine: Petitioner argued a POSITA would combine Tomita’s teachings to enhance the viewing options of the Kaminski-Son system. This would allow a user to simultaneously view two different programs (or different portions of the same program), and Tomita provided known, advantageous methods for displaying the corresponding control information without cluttering the screen.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 7-10 and 17-20 based on the four-way combination of Kaminski, Son, Safadi, and Tomita, arguing the combination of features was obvious.

4. Key Claim Construction Positions

  • "buffer memory": The petition argued for a Broadest Reasonable Construction (BRC) of "device or storage area used to store data temporarily." This construction was asserted to be critical because it encompasses storage devices like the hard disk drive (HDD) used for temporary buffering in Kaminski, which is central to the obviousness argument. Petitioner contended this interpretation is consistent with the patent's specification and contemporaneous technical dictionaries.
  • "time length": The petition proposed that for the purposes of the IPR, "time length" should be construed to mean "duration of time" where the indication can be either quantitative (e.g., a numerical time) or qualitative (e.g., a representational bar). This construction was argued to be consistent with the plain meaning and a position previously taken by the Patent Owner in a related ITC action.

5. Relief Requested

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