PTAB

IPR2025-00351

Stingray Group Inc v. Hernandez MonDragon Edwin

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Petition

1. Case Identification

2. Patent Overview

  • Title: Broadcasting Multimedia Content and Assembling Media Streams
  • Brief Description: The ’441 patent relates to systems for broadcasting multimedia content. The technology is directed to two main methods: creating custom HTML user interfaces which are then encapsulated into an MPEG transport stream for delivery (claims 1-9), and rendering a webpage using a browser, generating a temporal sequence of screen captures of that page, and assembling the captures into a media stream for broadcast (claims 10-26).

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1 and 7 by Farber

  • Prior Art Relied Upon: Farber (Patent 7,940,303).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Farber, which discloses an audio broadcast system for transmitting music channels over a network, teaches every limitation of independent claim 1. Farber describes creating a "multimedia asset" (a music channel comprising audio and a corresponding user interface) where the interface is coded using HTML and may include video. This asset is then encoded and multiplexed with audio into an MPEG transport stream. Petitioner asserted that Farber’s "storage/playout device" is a caching unit that stores the created MPEG stream for later playback, which occurs in response to a request from a broadcasting unit (the distribution system). For dependent claim 7, Petitioner pointed to Farber’s disclosure that the user interface assets can contain "motion picture video content," which is taken from a media file.

Ground 2: Obviousness of Claims 10-16 and 18-23 over Avellan and Pavlovskaia-PCT

  • Prior Art Relied Upon: Avellan (Patent 8,954,600) and Pavlovskaia-PCT (WO 2010/044926).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Avellan teaches the core functionality of independent claim 10. Avellan describes a "gateway server" that includes browser software to access and render web pages from sources like CNN or YouTube. This server "continuously captures images of the web page" to create a temporal sequence of screen captures, which illustrates dynamic content changes over time. These captures are then assembled and compressed into a video format that is provided to a content provider (user computers) for broadcast.
    • Motivation to Combine: Pavlovskaia-PCT teaches using a virtual machine to orchestrate the process of obtaining web content, rendering it, and encoding it into an MPEG video stream. A POSITA would combine Avellan’s system with Pavlovskaia-PCT’s virtual machine implementation because virtualization is an efficient, scalable, and cost-effective method for deploying server-side content delivery systems like Avellan's. Both references address the same technical field of rendering web content for video stream delivery.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination. Avellan’s server-based architecture is inherently compatible with virtualization, and implementing it on a virtual machine as taught by Pavlovskaia-PCT would not require altering its fundamental operation.

Ground 3: Anticipation of Claim 26 by Avellan

  • Prior Art Relied Upon: Avellan (Patent 8,954,600).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Avellan anticipates all limitations of independent claim 26. Avellan discloses the core process: a caching unit (gateway server) receives a request, obtains web content, renders it, generates a temporal sequence of screen captures, assembles them into a media stream, and provides the stream via a multicasting unit. For the final limitations, Avellan teaches "storing" the compressed video format in its gateway cache (recording the media stream) and using "more than one server 134" for "redundancy." Petitioner asserted that this disclosure of redundancy inherently teaches that upon a fault being detected at one caching unit, a pre-recorded stream from another would be provided.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 1-9 based on Farber in combination with Vermeulen (for storage space checks), Pavlovskaia (for JavaScript UIs), Davis (for specific bit rates and codecs like H.264/AC-3), and Fogel (for WebKit rendering). Additional challenges against claims 15, 16, 17, and 24 were based on Avellan and Pavlovskaia-PCT in view of secondary references teaching metadata, channel identifiers, MPEG format querying, and JSON APIs.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) or §325(d) is not warranted. The core arguments were that the petition relies on prior art never considered during prosecution that discloses key elements the Patent Owner previously characterized as an "important distinction" over the art of record. Additionally, the co-pending district court litigation is in a very early stage, and Petitioner intends to seek a stay pending the outcome of the IPR.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-26 of Patent 11,140,441 as unpatentable.