PTAB

IPR2025-00057

Amazon.com Inc v. BSD Crown Ltd

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Emulating a Mobile Device
  • Brief Description: The ’887 patent discloses a system for decoupling a mobile device's hardware (HW) capabilities from its performance and user experience. This is achieved by emulating the mobile device—including its operating system (OS) and applications—on a remote server, which processes user inputs from the physical device and streams the resulting user interface back to the device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yoon - Claims 1-3, 5, 20-21, and 28 are obvious over Yoon.

  • Prior Art Relied Upon: Yoon (Korean Patent Application Publication No. 10-2012-0046807).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yoon disclosed all limitations of the challenged independent claims. Yoon taught a system where a virtualization server emulated a mobile OS and applications. A user terminal sent unprocessed input to the server, which executed the OS, processed the input, and streamed the resulting user interface (e.g., screen image and sound) back to the terminal for reproduction. Petitioner contended that for claims requiring processing based on a "same instance" of the mobile device OS (claims 1, 20), Yoon’s disclosure of a single emulation instance serving one or more terminals met this limitation, as using multiple instances for a single terminal would be illogical and inefficient. For claim 28, which required processing by different OS instances, Petitioner argued Yoon’s disclosure of providing multiple OS stack layers, each of which could emulate a different OS, rendered this limitation obvious.
    • Key Aspects: This ground established Yoon as a primary reference that taught the core architecture of the challenged claims: server-side emulation of a mobile device OS, with input sent from the client and a user interface streamed back.

Ground 2: Obviousness over Yoon and Nix - Claims 4, 14, and 22 are obvious over Yoon in view of Nix.

  • Prior Art Relied Upon: Yoon (KR 2012/0046807), Nix (Application # 2006/0098619).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Nix to the teachings of Yoon to address claims requiring a "mobile device gateway for handling and providing internet access, voice calls and a gateway to a public switched telephone network (PSTN)." Petitioner asserted Yoon's web server, integrated into its virtualization server, provided the gateway for internet access. Nix was cited for its teaching of a packet-switched telephony service that used a gateway to connect internet-based devices to the PSTN for making voice calls.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references to add internet telephony—a common web service—to Yoon's virtualized environment. This would provide users with the known benefits of internet telephony (e.g., cheaper calls) and allow terminals without native access to use this feature via the server, a stated goal of systems like Yoon's.
    • Expectation of Success: The combination involved applying a known technique (Nix's server-based PSTN gateway) to a known system ready for improvement (Yoon's server) to achieve the predictable result of providing internet calling capabilities to the emulated mobile device.

Ground 3: Obviousness over Yoon, Lubonski, and Richardson - Claims 6-8, 11-13, 15-17, and 23-25 are obvious over Yoon in view of Lubonski and Richardson.

  • Prior Art Relied Upon: Yoon (KR 2012/0046807), Lubonski (a 2005 article on an adaptation architecture for Quality of Service), and Richardson (a 2010 textbook on the H.264 video compression standard).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the user interface stream to comprise different data types sent in "separate data stream[s]," with different Quality of Service (QoS) levels, encoding methods, or bandwidths. Petitioner argued Yoon taught sending a stream with different data types (video and audio). Lubonski was cited for its teaching of a server-side architecture that classifies different data flows (e.g., video, audio) and dynamically adjusts resource allocation (like bandwidth) to preserve user-perceived QoS for each flow. Richardson was cited to explain how data encoded with H.264 (as taught by Yoon) is transported using protocols like Real-Time Transport Protocol (RTP), which uses payload type identifiers to distinguish between data types like video and audio, enabling the classification taught by Lubonski.
    • Motivation to Combine: Petitioner asserted a POSITA implementing Yoon’s system, which streamed multimedia, would have been motivated to improve the user experience by managing QoS, a well-known concern. Lubonski provided an explicit solution for improving user-perceived QoS in a remote desktop environment. To implement Lubonski's packet classifier on Yoon's H.264 data, a POSITA would have consulted an authoritative source like Richardson, which taught using RTP and its type identifiers to distinguish data flows.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references because it involved applying a known QoS improvement technique (Lubonski) to a standard multimedia streaming system (Yoon) using a standard transport protocol (RTP, as detailed in Richardson) to achieve the predictable result of better user-perceived quality.

  • Additional Grounds: Petitioner asserted parallel sets of obviousness challenges based on Overton (Patent 9,424,052) and Lu (Application # 2009/0305790) as alternative primary references. These grounds mirrored the structure of the Yoon-based grounds, combining Overton and Lu with Nix for gateway functionality claims and with Lubonski and Richardson for QoS and separate data stream claims.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under the Fintiv factors would be inappropriate and that the Board should institute review. Petitioner contended that although a parallel district court case exists, the median time to trial in that venue (N.D. Cal.) would place the trial date well after the statutory deadline for a Final Written Decision (FWD) in the IPR. Furthermore, Petitioner argued it filed the petition at an early stage of the litigation, before invalidity contentions were due, and that the IPR challenges a broader set of claims than are asserted in the district court case. Petitioner asserted that these factors, combined with the compelling merits of the petition, weigh strongly in favor of institution.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-8, 11-17, 20-25, and 28 of the ’887 patent as unpatentable.