PTAB

IPR2024-00699

Vizio Inc v. Multimedia Technologies Pte Ltd

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1. Case Identification

2. Patent Overview

  • Title: Data Service System for an Intelligent Television
  • Brief Description: The ’805 patent describes a data service system for an Intelligent Television (TV) that receives media, content, and related metadata from a plurality of sources, or "subservices," such as video-on-demand (VOD) and electronic program guides (EPG). The system organizes the received data into a uniform format using pre-defined data models and provides the organized data to various content provider modules on the TV.

3. Grounds for Unpatentability

Ground 1: Obviousness over Melnychenko and Chen - Claims 1, 10, and 17 are obvious over Melnychenko in view of Chen.

  • Prior Art Relied Upon: Melnychenko (Application # 2013/0263184) and Chen (Application # 2007/0226268).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Melnychenko discloses an interactive media guidance system for a TV that receives content and metadata from various sources (VOD, EPG, Internet), corresponding to the claimed "plurality of subservices." However, Melnychenko teaches that this metadata may arrive in a "variety of metadata formats" but does not detail how to process it for unified storage. Petitioner asserted that Chen remedies this deficiency by teaching a method to manage metadata from multiple media types by organizing it into a "uniform format" using a "specific table" for each data type. The combination allegedly teaches receiving data from different subservices (Melnychenko) and organizing that data into a pre-defined, uniform format for use by the TV (Chen).
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) implementing Melnychenko’s system would need an efficient way to handle metadata from disparate sources. Petitioner contended a POSITA would combine Chen’s teachings to solve this problem, as Chen explicitly addresses organizing varied metadata into a uniform format to simplify storage, improve data retrieval, and facilitate user interface design.
    • Expectation of Success: Petitioner argued that Chen’s method of organizing metadata is a general technological principle not limited to specific content types. Therefore, a POSITA would have a high expectation of success in applying Chen's universally applicable data organization techniques to the various content streams disclosed in Melnychenko.

Ground 2: Obviousness over Melnychenko, Chen, Kim, and Lee-1 - Claims 1-3, 6, 10-12, and 16-18 are obvious over Melnychenko in view of Chen, Kim, and Lee-1.

  • Prior Art Relied Upon: Melnychenko (Application # 2013/0263184), Chen (Application # 2007/0226268), Kim (Application # 2012/0054794), and Lee-1 (Patent 9,008,190).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the Melnychenko/Chen combination by adding references to address dependent claims related to the user interface and specific "content provider modules." Petitioner asserted that Kim teaches a smart TV with an improved graphical user interface that uses an On-Screen Display (OSD) generator to create and display "card objects" for different content sources (e.g., a TV Guide card, My Media card, Channel Browser card). These card-generating functional programs were argued to correspond to the claimed "EPG data provider," "media browser," and "media scanner." Petitioner further argued that Lee-1, which is incorporated by reference in Kim, discloses a "thumbnail generator" that provides the technical details for creating thumbnails for media and applications, corresponding to the claimed "thumbnail engine."
    • Motivation to Combine: Petitioner argued that a POSITA would be motivated to enhance the basic grid guide of the Melnychenko/Chen system with the more modern and intuitive card-based home screen taught by Kim to improve the user experience. This was presented as a known design choice for improving graphical interfaces. Since Kim explicitly incorporates Lee-1 for its teachings on thumbnails, a POSITA implementing Kim's interface would naturally turn to Lee-1 for the details of thumbnail generation.
    • Expectation of Success: The integration of a card-based UI and thumbnail generation was framed as a matter of routine software programming. A POSITA would have expected predictable results in improving the usability of the Melnychenko/Chen system by applying the known interface techniques from Kim and Lee-1.

  • Additional Grounds: Petitioner asserted additional obviousness challenges:

    • Ground 3 (Claims 4, 13) added Lee-2 (Patent 9,398,339) for teachings on personalizing content, such as a favorite channel list.
    • Ground 4 (Claim 5) added Ferren (Patent 8,893,184) for its disclosure of using an SQLite database to store media metadata.
    • Ground 5 (Claims 6-8, 14, 15) added Choi (Application # 2013/0057764) for teachings on providing a real-time view of connected media sources with specific icons.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) based on Fintiv factors would be inappropriate. It contended that co-pending district court litigation is in its early stages and, crucially, stipulated that if the IPR is instituted, it will not pursue in court the specific grounds asserted in the petition or any other grounds that could have been reasonably raised.
  • Petitioner also argued that denial under §325(d) is not warranted because the asserted prior art and arguments are not cumulative or redundant to those considered by the Examiner during the original prosecution of the ’805 patent.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of Patent 10,419,805 as unpatentable under 35 U.S.C. §103.