PTAB

IPR2019-00743

Unified Patents LLC v. Ortiz & Associates Consulting LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of Brokering Video Data Between Handheld Wireless Devices and Video-Enabled Data Rendering Devices
  • Brief Description: The ’914 patent describes methods for providing video data to video-enabled display devices (e.g., monitors, projectors) at the request of wireless handheld devices. The system allows a user of a wireless device to locate a nearby rendering device and direct video content to be displayed on it.

3. Grounds for Unpatentability

Ground 1: Obviousness over Eldridge and Thomason - Claims 1-4, 8, 9, 16, and 18 are obvious over Eldridge in view of Thomason.

  • Prior Art Relied Upon: Eldridge (Patent 6,430,601) and Thomason (Patent 6,317,039).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Eldridge taught the core framework of the challenged claims. Eldridge disclosed a system where a mobile computing device (the claimed wireless device or "WD") could select a document—which may include video data—and request it be rendered on a networked data rendering device ("DRD"), such as a printer or an "audio-visual view station." Eldridge further taught locating available DRDs on a network and using an authorization code (a "document token") that is verified before the data is provided to the DRD. Petitioner contended that while Eldridge suggested rendering on an audio-visual station, it did not explicitly detail a video monitor. Thomason was introduced to supply this element, as it disclosed a system where video signals from a remote wireless device were transmitted over a network for display on a video monitor at a central station. The combination of Eldridge's authenticated data-brokering system with Thomason's explicit teaching of a networked video monitor allegedly rendered the limitations of independent claims 1, 9, and 16 obvious.
    • Motivation to Combine: A POSITA would combine these references to improve the system in Eldridge. Since Eldridge already taught handling video data and suggested output to an "audio-visual view station," it would have been a simple and predictable design choice to use a conventional video monitor, as taught by Thomason, as the rendering device. This combination would predictably result in the display of video data, which was a known purpose for both references.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because combining a known data rendering system (Eldridge) with a known type of display device for that data (Thomason's video monitor) used known methods to yield a predictable result.

Ground 2: Obviousness over Eldridge, Thomason, and Kim - Claims 5 and 6 are obvious over Eldridge and Thomason in view of Kim.

  • Prior Art Relied Upon: Eldridge (Patent 6,430,601), Thomason (Patent 6,317,039), and Kim (Patent 6,681,120).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Eldridge and Thomason to address claims 5 and 6, which required that video data be provided for rendering directly from said WD. The primary combination of Eldridge and Thomason taught retrieving the video data from a remote network server. Petitioner argued Kim supplied the missing element. Kim disclosed an internet-connected cell phone with an integrated video camera capable of capturing, storing, and transmitting its own video data directly to other devices (e.g., another phone or personal computer) for rendering.
    • Motivation to Combine: A POSITA would have been motivated to modify the Eldridge/Thomason system to include the local capture and direct transmission capability taught by Kim. This modification would add a desirable feature not present in Eldridge's token-based server-retrieval system, allowing for quicker use and transmission of locally captured video, particularly in an emergency. This was presented as the application of a known technique (local capture and direct transmission) to improve a similar device (Eldridge's WD) in a predictable way.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Kim demonstrated that such modifications for local video capture and transmission were commercially available at the time, using standard internet connectivity.

4. Key Claim Construction Positions

  • "brokering video data" (Claims 1-8, 16-20): Petitioner argued this term should be construed based on its definition in the ’914 patent’s specification. The specification stated, “Data Brokering includes the negotiation, management, coordination and/or facilitation of data movement and use between and throughout DRDs [data rendering devices], WDS [wireless devices] and networks.” Based on this, Petitioner contended a POSITA would understand the term to mean at least "the negotiation, management, coordination and/or facilitation of video data movement and use between and throughout devices and at least one network." This construction was central to mapping Eldridge's system of managing document movement across a network to the claims.

5. Relief Requested

  • Petitioner requested the Board to order an inter partes review trial for claims 1-6, 8, 9, 16, and 18 and then cancel these claims as unpatentable.