PTAB

IPR2019-00477

Unified Patents Inc v. hertl Media LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Processing Multimedia Data Streams with Multi-Language Audio
  • Brief Description: The ’365 patent relates to a data processor for multimedia streams that aims to solve latency problems when switching between language-specific content, such as different audio tracks. The system uses an input buffer for the main data stream and a plurality of parallel queues, where each queue is dedicated to a specific language and stores only references pointing to the language-specific content within the input buffer, rather than the content itself, to enable rapid switching with reduced memory overhead.

3. Grounds for Unpatentability

Ground 1: Claims 1-17 are obvious over Gordon in view of Yamada

  • Prior Art Relied Upon: Gordon (Application # 2008/0101421) and Yamada (Patent 5,610,914).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gordon disclosed a system for processing multi-language audio data from a multiplexed stream, including a data stream analyzer (processor 305) and a plurality of parallel FIFO queues (FIFOs 120a) for different language streams to enable rapid switching. However, Gordon's queues buffer the actual media streams, not references. Petitioner asserted that Yamada, which relates to general multi-stream buffering, taught the remaining limitations: a shared buffer memory that serves as the claimed "input buffer" and a plurality of parallel FIFO queues that store only "address pointers" (i.e., references) to the content held in the shared buffer. Combining Gordon's multimedia application with Yamada's efficient memory architecture allegedly rendered all limitations of the independent claims obvious.
    • Motivation to Combine: A POSITA would combine Yamada's known and efficient buffering technique with Gordon's system to improve the device by reducing latency and system cost. Petitioner argued that substituting Gordon's multiple large media buffers with Yamada's single large content buffer and smaller reference queues was a predictable solution. This is because storing small address references is orders of magnitude cheaper and faster than storing and managing duplicative, large multimedia streams. Petitioner cited established legal precedent to support that this substitution involved the use of a known technique to improve a device, a classic rationale for obviousness.
    • Expectation of Success: Petitioner contended the combination involved using familiar elements (buffers, FIFOs) to obtain predictable results. Yamada's architecture was described as a general solution for saving bandwidth and power in any application buffering multiple data streams, making it directly applicable to Gordon's system with only routine engineering work required for implementation.

Ground 2: Claims 1-17 are obvious over Gordon in view of Brown

  • Prior Art Relied Upon: Gordon (Application # 2008/0101421) and Brown (Patent 6,868,225).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner again relied on Gordon for the base system of processing multi-language media using parallel queues. Brown, a DVR patent, was cited for teaching the use of an "input buffer" (hard disk storage 105) and an "Event Buffer" that stores "logical segments" which act as references to the audio and video content stored in the input buffer. These references contain timestamps and memory addresses, allowing the system to index and access the content without copying it. Petitioner argued that replacing the actual content in Gordon's parallel audio queues with Brown's reference-based logical segments would have been an obvious modification that rendered the claims unpatentable.
    • Motivation to Combine: A POSITA would have been motivated by the performance benefits described in Brown, such as reduced memory and processor bandwidth usage, to incorporate its reference-based indexing into Gordon's system. This modification would allow Gordon's system to retrieve different language streams simply by looking up addresses in the parallel queues, avoiding the need to parse an "immense data stream," a clear advantage that would motivate a skilled artisan. This was presented as applying a known technique to improve a similar device to yield predictable benefits.
    • Expectation of Success: Petitioner asserted that modifying Gordon's system to incorporate Brown's use of logical segments was well within the skill of a POSITA. The combination involved known elements operating in a familiar way to achieve predictable improvements. Since the structures in Brown and Gordon were similar, the integration would require only routine engineering and would have a high likelihood of success.

4. Key Claim Construction Positions

  • "language-specific contents": Petitioner proposed that this term should be construed to include "an audio stream, a subtitle, a presentation graphic, an interactive graphic, and a credit section of an audio and video presentation," which is consistent with the explicit definition provided in the patent's specification. Petitioner submitted that all other terms should be given their plain and ordinary meaning.

5. Key Technical Contentions (Beyond Claim Construction)

  • The petition's central technical argument, supported by both Yamada and Brown, was that the core inventive concept of the ’365 patent—storing references to media data in parallel buffers rather than the media itself—was a well-known and conventional technique in the prior art at the time of the invention. Petitioner contended this architecture was a common design choice used to manage large data streams efficiently, save CPU power, reduce memory costs, and lower system latency. Therefore, its application in the specific context of multi-language media playback was presented as an obvious, rather than inventive, step.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review of claims 1-17 of Patent 9,324,365 and that those claims be found unpatentable and cancelled.