PTAB
IPR2023-00996
Sony Interactive Entertainment LLC v. Quantum Imaging LLC
1. Case Identification
- Case #: IPR2023-00996
- Patent #: 10,991,165
- Filed: June 6, 2023
- Petitioner(s): Sony Interactive Entertainment LLC
- Patent Owner(s): Quantum Imaging LLC
- Challenged Claims: 1-3, 5-8, 10-12, and 18
2. Patent Overview
- Title: Interactive Virtual Thematic Environment
- Brief Description: The ’165 patent relates to a method and system for an interactive software platform that integrates real-time information, such as audio and video, into a virtual thematic environment using a client-server computer system.
3. Grounds for Unpatentability
Ground 1: Claims 1-3, 5-8, 10-12, and 18 are obvious over Pisanich in view of the knowledge of a POSITA.
- Prior Art Relied Upon: Pisanich (International Publication No. WO 02/062436).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Pisanich taught a method for integrating real-time data into a gaming application, which serves as the claimed "virtual thematic environment." Pisanich's client-server system, comprising a "Game Data Server" and a "Game" on a player's computer, allegedly disclosed the claimed architecture. Petitioner mapped Pisanich’s rendering engine and input controls (joystick, keyboard) to the "graphics user interface (GUI) module." The "Game Data Server," which gathers, interprets, and provides real-time data to different games and players, was asserted to disclose the "quantum imaging environment (QIE) module." Pisanich’s "Rule-Based Logic Module" for aircraft operation was mapped to the "thematic/publishing logic module." The game itself served as the "primary application," while internal components like the audio engine and traffic manager, which process real-time data, were identified as "secondary applications." Pisanich's disclosure of requesting and receiving real-time weather data and air traffic communications was mapped to the claimed steps of obtaining first and second real-time information.
- Motivation to Combine: A POSITA would have been motivated to apply their ordinary skill—such as using standard internet protocols (e.g., HTTP) for requesting and transmitting data over the World Wide Web—to implement the client-server gaming system described by Pisanich. This was presented as a predictable design choice to achieve the system's intended functionality.
- Expectation of Success: A POSITA would have had a reasonable expectation of success in using known web technologies to fetch real-time data for integration into a gaming environment, as this was a conventional application of client-server networking principles.
Ground 2: Claims 1-3, 5-8, 10-12, and 18 are obvious over the PSO Manual in view of the knowledge of a POSITA.
- Prior Art Relied Upon: Phantasy Star Online Manual ("PSO Manual").
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted the PSO Manual, describing the online multiplayer game Phantasy Star Online, disclosed all limitations of the challenged claims. The game itself, played on a Sega Dreamcast console (client) connected to a "PSO server," was argued to be the claimed "primary application" within a "virtual thematic environment." The game's on-screen display and controller interface constituted the "GUI module." The game's networking functionality, which received and interpreted data from players on different systems (including a "Word Select" feature for language translation), was argued to be the "QIE module." The inherent game logic and rules were mapped to the "thematic/publishing logic module." Real-time information on remote player movements was identified as the "first real-time information," while the in-game chat and mail systems were presented as "secondary applications" that provided the "second real-time information" (chat messages).
- Motivation to Combine: A POSITA would have been motivated to implement the described online game using their general knowledge of client-server architecture, network communications for multiplayer gaming, and user interface design. The combination of these well-known elements to create the system described in the PSO Manual would have been a matter of applying routine skill to a known problem.
- Expectation of Success: A POSITA would have reasonably expected success in building the online game system as described, since it relied on established principles of networked applications and graphical user interfaces prevalent at the time.
4. Key Claim Construction Positions
- For the purpose of the petition only, Petitioner adopted constructions from a court order in a related case involving patents from the same family. Petitioner argued the prior art met these constructions but reserved the right to propose alternative constructions in district court litigation.
- "graphics user interface (GUI) module": "software that provides a graphical display and processes user inputs to allow a user to interact with the graphical display."
- "quantum imaging environment (QIE) module": "a software layer which receives and interprets content such that the content is manipulated so as to be accessible on different types of devices for use within the virtual thematic environment."
- "virtual thematic environment": "a theme-based virtual computer interface."
5. Arguments Regarding Discretionary Denial
- Petitioner argued against discretionary denial under §314(a) based on the Fintiv factors, asserting that the parallel district court litigation was in a very early stage.
- Key arguments included: no stay had been requested or granted in the parallel case; the scheduled trial date was distant (April 2024 at the earliest) and likely to be delayed further; investment by the court and parties in the parallel case was minimal; and instituting the inter partes review (IPR) would efficiently narrow the issues for litigation due to statutory estoppel provisions. Petitioner also stipulated that it would not pursue in the district court the same grounds raised in the IPR if review were instituted.
6. Relief Requested
- Petitioner requests institution of IPR and cancellation of claims 1-3, 5-8, 10-12, and 18 of the ’165 patent as unpatentable.