PTAB

IPR2020-01338

Unified Patents LLC v. Ideahub Inc

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Method for Providing Media Using Metadata
  • Brief Description: The ’562 patent discloses a method for providing media content to an end-user terminal. The method involves receiving metadata, such as a Media Presentation Description (MPD), which includes one or more BaseURL elements that specify common locations for media segments. A client then requests a specific media segment using a URL that is resolved with respect to a BaseURL element, receives the segment, and performs decoding and rendering.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chen and OAI - Claims 1 and 2 are obvious over Chen in view of OAI.

  • Prior Art Relied Upon: Chen (Application # 2011/0099594) and OAI (“The Open Archives Initiative Protocol for Metadata Harvesting,” Protocol Version 2.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chen teaches a method for providing streaming media that meets most limitations of claim 1. Chen describes a client device retrieving presentation description data (an MPD file) that contains a URL for a source device. The client then constructs and sends an HTTP GET request for a specific media segment (a 3GPP file) using this URL. However, Chen does not explicitly describe its base URL as being an XML element. OAI, a protocol for metadata harvesting, remedies this by disclosing the use of an XML-based metadata document that explicitly defines a baseURL element to specify the location of a repository. OAI further teaches that a metadata document can contain multiple baseURL elements to point to different repositories.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Chen and OAI because both references are from the same field of providing metadata to facilitate HTTP access to media content. A POSITA would implement Chen’s MPD file using the well-known and efficient XML syntax taught by OAI. The motivation would be to leverage a standardized, widely used format (XML) for exchanging information. Furthermore, incorporating OAI’s teaching of multiple BaseURL elements into Chen’s system would have been a known technique to improve quality of service by enabling client devices to access alternative servers for load balancing and improved responsiveness.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved the simple substitution of a known element (Chen’s base URL string) for another known format (OAI’s XML baseURL element). This would have been achievable using routine markup language skills to produce the predictable result of a more robust and flexible media delivery system.

Ground 2: Obviousness over Chen, OAI, and 3GPP - Claims 3-9 are obvious over Chen in view of OAI and 3GPP.

  • Prior Art Relied Upon: Chen (Application # 2011/0099594), OAI (“The Open Archives Initiative Protocol for Metadata Harvesting,” Protocol Version 2.0), and 3GPP (3GPP TS 26.234 V9.2.0 (2010-03)).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that the combination of Chen and OAI, as established in Ground 1, would be further modified in view of 3GPP to arrive at the limitations of dependent claims 3-9. 3GPP is a technical specification for packet-switched streaming services that discloses an adaptive HTTP streaming protocol. Crucially, 3GPP provides a detailed XML schema for an MPD file that includes specific features recited in the challenged dependent claims. These features include: organizing media into a sequence of "periods" (claim 3); defining baseURLs at different hierarchical levels, such as the overall MPD level and the period level (claims 3, 6, 9); including a range attribute to request a specific contiguous range of bytes from a resource (claim 4); and specifying that a URL can be either absolute or relative (claim 7).
    • Motivation to Combine: Petitioner argued that a POSITA seeking to implement the system of Chen and OAI would have been motivated to consult an established industry standard like 3GPP. 3GPP provided a ready-made, detailed XML schema for the very type of MPD file central to the invention. Adopting 3GPP’s schema would provide a standardized way to implement advanced features like hierarchical base URLs for greater flexibility and byte-range requests for more efficient data retrieval. This would have been seen as a natural design choice to improve the system’s functionality and ensure interoperability.
    • Expectation of Success: The combination would have yielded predictable results. A POSITA would have been simply applying the specific, well-documented schema of the 3GPP standard to the media streaming framework taught by Chen. This modification would involve routine editing of the MPD file to incorporate standardized attributes and elements, which was well within the skillset of a POSITA at the time.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9 of the ’562 patent as unpatentable under 35 U.S.C. §103.