Stingray Group Inc v. Hernandez MonDragon Edwin

1. Case Identification

• Case #: IPR2025-00350
• Patent #: 10,524,002
• Filed: December 20, 2024
• Petitioner(s): Stingray Group Inc. and Stingray Music USA, Inc.
• Patent Owner(s): Edwin A. Hernandez-Mondragon
• Challenged Claims: 1-13

2. Patent Overview

• Title: Media Content Delivery System
• Brief Description: The ’002 patent discloses computer-implemented methods and systems for obtaining multimedia content from a source like a website, rendering that content, and generating a media stream from a temporal sequence of screen captures for broadcast on a media channel.

3. Grounds for Unpatentability

Ground 1: Obviousness over Avellan - Claims 1-6 and 13 are obvious over Avellan.

• Prior Art Relied Upon: Avellan (Patent 8,954,600).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Avellan discloses the core method of the ’002 patent. Avellan teaches a gateway communication system that receives user requests for web content, retrieves the content from the internet using a remote virtual browser, renders the webpage, and "continuously captures images of the web page" to create a compressed video stream for broadcast. This process was asserted to teach the limitations of receiving a request, obtaining content, rendering a webpage, generating a temporal sequence of screen captures, assembling a media stream, and providing it for broadcast, as required by independent claims 1, 4, and 13.
  • Motivation to Combine: This is a single-reference obviousness challenge. Petitioner contended that any claim elements not explicitly disclosed in Avellan would have been obvious modifications. For instance, Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to use well-known streaming protocols like HTTP Live Streaming (HLS) or Real-Time Streaming Protocol (RTSP) to implement Avellan’s "live streaming television feeds" for improved efficiency and compatibility. Similarly, implementing Avellan's process using parallel threads to speed up rendering would have been an obvious optimization.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying standard, widely-used streaming protocols and parallel processing techniques to Avellan’s disclosed system to achieve predictable improvements in performance.

Ground 2: Obviousness over Avellan, Ma, and Fain - Claims 1-6 and 13 are obvious over Avellan in view of Ma and Fain.

• Prior Art Relied Upon: Avellan (Patent 8,954,600), Ma (Application # 2014/0150019), and Fain (a 2011 Java programming textbook).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground used Avellan as the base system for the core method steps. Ma was introduced to teach specific streaming protocols and interactive features missing from Avellan, such as using HLS, HTTP playlists, and inserting metadata into MPEG-TS packets for interactivity. Fain was cited for its explicit teachings on multi-threading, particularly how web browsers use multiple parallel threads to download and render web content efficiently.
  • Motivation to Combine: A POSITA would combine Avellan with Ma to implement a robust, standardized protocol (HLS) for delivering the live streaming content Avellan describes, thereby improving interoperability and performance. The motivation to add Fain’s teachings was to implement Avellan’s parallel processing capability using multi-threading, a conventional technique for improving the speed and efficiency of software like a web browser, especially in multi-processor systems. Petitioner argued the combinations were simple applications of known technologies to solve predictable problems.
  • Expectation of Success: A POSITA would have reasonably expected success in combining these references, as it involved applying a standard streaming protocol (Ma) and a fundamental programming technique (Fain) to the general system architecture disclosed by Avellan.

Ground 3: Anticipation by Wannamaker - Claims 7-9 and 11-12 are anticipated by Wannamaker.

• Prior Art Relied Upon: Wannamaker (Application # 2004/0031052).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted Wannamaker anticipates the key elements of system claim 7. Wannamaker discloses a "middleware solution" for cable operators including an application server (a multicast server) and a content processor (a caching server) that are communicatively coupled. The system renders web content, including animated images like GIFs, into a temporal sequence of separate frames ("screen captures"). It assembles these frames into an MPEG video stream and provides it to the multicast server for broadcast. Wannamaker also explicitly discloses a monitoring system with fault tolerance and load balancing features to maintain generation of video files even in failure cases, directly mapping to other limitations of the challenged system claims. Dependent claims related to load balancing, broadband network communication, and adding metadata to MPEG frames were also argued to be expressly disclosed.

Ground 4: Obviousness over Wannamaker and Avellan - Claim 10 is obvious over Wannamaker in view of Avellan.

• Prior Art Relied Upon: Wannamaker (Application # 2004/0031052) and Avellan (Patent 8,954,600).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wannamaker’s system encodes video content into a streaming format (MPEG) but primarily describes a multicast/broadcast architecture. Avellan was cited for its explicit disclosure of a "unicast mode" for delivering customized, user-specific web content in real time.
  • Motivation to Combine: A POSITA would have been motivated to combine Wannamaker’s content processing and delivery system with Avellan’s unicast functionality. This combination would allow Wannamaker’s system to support individual user requests for specific content, a necessary feature for user interaction beyond simple broadcasting. Petitioner asserted this would be a predictable and desirable integration of known features from two similar server-side content delivery systems.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) or §325(d) is not warranted. It was contended that the primary prior art references (Avellan, Fain, and Wannamaker) were not considered during the original prosecution. Furthermore, the co-pending district court litigation was asserted to be in its early stages, and Petitioner intended to file a motion to stay that litigation pending the outcome of the IPR.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of Patent 10,524,002 as unpatentable.