PTAB

IPR2019-00555

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 Identifying and Storing a Portion of a Media Asset
  • Brief Description: The ’014 patent discloses systems for processing voice commands to retrieve, store, and play media assets. The technology involves receiving a voice command that includes a media asset identifier (MAI), searching a database for the MAI using fuzzy matching, calculating similarity metrics, and presenting the most likely results to the user for confirmation.

3. Grounds for Unpatentability

Ground A: Anticipation of Claims 1, 4, 6-8, 11, 14, 16-18 by Yates

  • Prior Art Relied Upon: Yates (Patent 8,316,394).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yates taught every limitation of the challenged claims. Yates described an interactive media guidance system that receives voice commands containing a "user preference" (the MAI) to search for media assets in an electronic program guide. If an exact match was not found, Yates performed a "fuzzy match" by calculating a relevance score ("degree of similarity") for available assets. Assets with scores exceeding a threshold were then selected and presented to the user as a list or as the highest-scoring option, providing an option to confirm the selection by recording or playing the asset.
    • Key Aspects: This ground asserted that Yates’s disclosure of a "fuzzy match" system with relevance scores directly read on the core method of independent claims 1 and 11, with its various features anticipating the dependent claims as well.

Ground C: Obviousness over Yates in view of Jurafsky - Claims 1, 4, 6-8, 11, 14, 16-18 are obvious over Yates in view of Jurafsky.

  • Prior Art Relied Upon: Yates (Patent 8,316,394) and Jurafsky (a 2000 textbook on speech and language processing).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that to the extent Yates did not sufficiently detail certain features, Jurafsky provided the missing teachings. Specifically, Jurafsky, a well-known textbook, taught standard techniques for voice recognition (digitizing speech, transforming signals, and decoding words) that could supplement Yates's voice recognition interface. Furthermore, Jurafsky taught a specific "vector-space model" for calculating similarity between text strings by summing the number of shared terms, which Petitioner contended was a well-known and suitable scoring function for implementing the "degree of similarity" calculation recited in the ’014 patent.
    • Motivation to Combine: A POSITA would combine Jurafsky with Yates to implement or improve Yates's system using known, fundamental techniques. Jurafsky’s vector-space model was described as a simple, fast, and effective algorithm for calculating similarity, making it a predictable and desirable improvement over more complex or less-defined scoring functions.
    • Expectation of Success: A POSITA would have a high expectation of success, as Jurafsky’s teachings were authoritative and described standard algorithms that used the same inputs (text strings) and produced the same type of output (a relevance score) as required by the Yates system, allowing for straightforward implementation.

Ground E: Obviousness over Yates, Jurafsky, Taranenko, and Wang - Claims 2 and 12 are obvious over Yates in view of Jurafsky, Taranenko, and Wang.

  • Prior Art Relied Upon: Yates (Patent 8,316,394), Jurafsky (a 2000 textbook), Taranenko (Application # 2008/0319990), and Wang (a 2007 programming textbook).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claims 2 and 12, which specified a character-by-character method for calculating the degree of similarity. Petitioner argued Taranenko taught this exact method. Taranenko disclosed a weighted, character-by-character comparison algorithm to calculate the proximity between two strings, assigning scores for exact character/position matches and near-matches. This algorithm directly mapped to the claimed steps of initializing a score, determining character matches at each position, and incrementing the score. Wang was cited for the basic programming principle of initializing variables to a default value (e.g., zero) before a calculation, a step implicit in Taranenko’s summation-based algorithm.
    • Motivation to Combine: A POSITA would combine Taranenko with the Yates/Jurafsky system because Taranenko’s algorithm was a suitable and more precise "scoring function" for implementing the fuzzy matching disclosed in Yates. It was a known technique for improving search precision by using weighted position and character matching.
    • Expectation of Success: Success was expected because Taranenko's algorithm used the same inputs (text strings) and produced the same output (a similarity score) as required by Yates, making it a predictable software routine to implement on Yates's hardware.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, including combinations of Yates with Hamano (Application # 2010/0333137) to teach filtering results based on user profiles and device identifiers (claims 5, 9, 15, 19), and with Wood (Patent 6,324,338) to teach managing insufficient storage space by prompting a user to delete existing content (claims 10, 20).

4. Key Claim Construction Positions

  • Means-Plus-Function Terms: Petitioner contended that the terms "Communications circuitry" (claim 11) and "Control circuitry configured to:" (claim 11) were means-plus-function terms under §112.
    • For "Communications circuitry," Petitioner identified the function as receiving a voice command and the corresponding structures from the specification as a microphone, user input interface, and various modems.
    • For "Control circuitry," Petitioner identified the functions as the steps recited in claims 11[d]-11[k] and the corresponding structure as "control circuitry 304" from the specification, which comprised processing circuitry and storage executing software.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of Patent 9,668,014 as unpatentable.