PTAB

IPR2019-01137

Charter Communications Inc v. Sprint Communications Co LP

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Video-on-Demand System Controlled via Computer
  • Brief Description: The ’907 patent describes a video-on-demand (VOD) system that allows a user to control video content display using a general-purpose computer instead of a dedicated set-top box. The system utilizes a first communication system with a high bandwidth to transfer video signals to a primary display (e.g., a television) and a second communication system with a lower bandwidth to transfer control screens and second video signals to the computer.

3. Grounds for Unpatentability

Ground 1: Claims 1-53 are obvious over Ellis and Yosuke.

  • Prior Art Relied Upon: Ellis (Patent 7,913,278) and Yosuke (European Patent Application EP 0 872 987 A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ellis discloses the core VOD system, including an interactive program guide remotely accessed and controlled by a portable device (e.g., a computer) to display content on either the device itself or on separate television equipment, thus replacing the traditional set-top box. However, Ellis does not explicitly teach using different bandwidths for the two display paths. Petitioner asserted that Yosuke remedies this by teaching a VOD system with two transmission lines: a high-bandwidth line for sending video to a main display and a lower-bandwidth line for a touch-panel control display. The combination of Ellis’s remote control architecture and Yosuke’s differential bandwidth scheme was alleged to teach all limitations of the independent claims.
    • Motivation to Combine: A POSITA would combine Ellis and Yosuke to enhance the interactive television system of Ellis with the known and advantageous dual-bandwidth transmission method taught by Yosuke. Both references are in the same field of VOD systems, address the same problem of replacing inflexible set-top boxes, and use similar computer-based control techniques, making the combination a predictable and logical step to improve system performance and user flexibility.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these references, as it involved integrating a known network architecture (Yosuke) into a compatible remote-control system (Ellis) without changing the fundamental principles of either.

Ground 2: Claims 1-53 are obvious over Ellis, Yosuke, and Browne.

  • Prior Art Relied Upon: Ellis (Patent 7,913,278), Yosuke (European Patent Application EP 0 872 987 A2), and Browne (WO 92/22983).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Ellis and Yosuke by adding Browne to supply teachings for specific control menu features. Petitioner argued that Browne discloses a VOD system with a virtual control screen that provides a user with playback controls, including "pause," "rewind," and "fast forward," as well as a "full screen mode" option. To the extent Ellis and Yosuke did not explicitly disclose these specific control functions recited in certain dependent claims, Browne was asserted to provide them.
    • Motivation to Combine: A POSITA building the system of Ellis and Yosuke would be motivated to incorporate the well-known user control features from Browne to create a more functional and commercially desirable product. Adding standard playback controls to a video display interface was a common and obvious practice in the art to improve the user experience.

Ground 3: Claims 1-53 are obvious over Ellis, Yosuke, and Humpleman.

  • Prior Art Relied Upon: Ellis (Patent 7,913,278), Yosuke (European Patent Application EP 0 872 987 A2), and Humpleman (Patent 6,182,094).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground uses Humpleman to supplement the teachings of Ellis and Yosuke, particularly regarding the implementation of the control interface. Petitioner contended that Humpleman teaches a browser-based system for controlling devices on a home network, where control screens are generated from HTML files and displayed on a second device. Humpleman also discloses features such as video previews via "picture-in-a-picture" functionality. These teachings were argued to meet limitations related to browser-based control screens (web pages) and video preview selections.
    • Motivation to Combine: A POSITA would be motivated to combine Humpleman with Ellis and Yosuke to implement the VOD control interface using flexible, standardized web-based technology. Using a browser-based approach as taught by Humpleman would allow for greater device compatibility and easier integration within a home network, representing a known and advantageous design choice for improving the system of Ellis and Yosuke.

4. Key Claim Construction Positions

  • Petitioner argued that key claim terms should be construed consistently with a claim construction order from a related district court case (Comcast v. Sprint).
  • Petitioner supported the court’s construction for terms like "video-on-demand system," which required operating the system "without the use of a set-top box for remote control." This construction was based on the ’907 patent’s own specification, which disparaged the prior art’s reliance on set-top boxes.
  • Petitioner asserted that all challenged claims are obvious over the cited prior art regardless of whether the Board adopts the court's constructions or the Patent Owner's broader proposed constructions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-53 of Patent 6,757,907 as unpatentable.