PTAB

IPR2025-00502

Samsung Electronics America Inc v. Koninklijke KPN NV

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Managing Associated Sessions in a Network
  • Brief Description: The ’669 patent discloses a method for managing networked multimedia systems by using a "composition session" to associate and collectively control multiple component media streams. A network element uses a "composition session identifier" to manage distinct streams (e.g., broadcast television, on-demand content) as a single user experience, enabling network-centric actions like pausing all associated streams simultaneously.

3. Grounds for Unpatentability

Ground 1: Claims 2-6, 8, and 14-20 are obvious over Widegren in view of Widegren-793.

  • Prior Art Relied Upon: Widegren (Application # 2002/0120749) and Widegren-793 (Patent 6,621,793).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Widegren discloses the core concept of the ’669 patent: a "multimedia session" within an IP Multimedia Subsystem (IMS) that uses a "session identifier" to manage and apply policy controls to multiple associated media streams. Widegren allegedly teaches establishing this separate signaling session to manage the associated data streams. Petitioner contended that the combination with Widegren-793 renders obvious the limitation of modifying the composition session to terminate all associated sessions, as Widegren-793 explicitly discloses a "session termination" event that terminates a session and its associated network bearers.
    • Motivation to Combine: A POSITA would combine these references because they address related quality-of-service issues in IMS networks, share common inventors, and are assigned to the same entity (Ericsson). Critically, Widegren expressly identifies the technology in Widegren-793 as a "desirable policy control approach," providing a clear reason to integrate its session termination functionality into Widegren's multimedia session management framework.
    • Expectation of Success: A POSITA would have a high expectation of success because both references are based on well-known, standardized technologies like IMS and Session Initiation Protocol (SIP), making the integration of a termination function a predictable application of known techniques.

Ground 2: Claims 7 and 9 are obvious over Widegren and Widegren-793, in further view of ETSI TS 183 063.

  • Prior Art Relied Upon: Widegren (Application # 2002/0120749), Widegren-793 (Patent 6,621,793), and ETSI TS 183 063 (a June 2008 technical specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the base combination of Widegren and Widegren-793. Petitioner asserted that the ETSI technical specification supplies the specific types of associated sessions recited in dependent claims 7 and 9. ETSI explicitly describes protocols for IPTV services on an IMS architecture, including broadcast (BC) sessions, content-on-demand (CoD) sessions, and network personal video recorder (nPVR) services, along with their associated identifiers.
    • Motivation to Combine: A POSITA seeking to implement Widegren's session management system for video applications would be motivated to consult a standard like ETSI to provide common IPTV functionalities. Given that all three references build on the same underlying IMS and SIP technology, applying the specific IPTV services from ETSI to the general session management framework of Widegren would be a logical step to enhance functionality and meet consumer demand.
    • Expectation of Success: Success would be reasonably expected, as ETSI is a standard specifically designed to implement IPTV services over the same type of IMS architecture disclosed in Widegren.

Ground 3: Claims 13 and 23 are obvious over Widegren and Widegren-793, in further view of Astrom.

  • Prior Art Relied Upon: Widegren (Application # 2002/0120749), Widegren-793 (Patent 6,621,793), and Astrom (WO 2007/101473).
  • Core Argument for this Ground:
    • Prior Art Mapping: Building on the primary combination, Petitioner introduced Astrom to teach the limitations of claims 13 and 23. Astrom discloses an IPTV system built on an IMS architecture that includes a Service Control Function (SCF), as required by claim 13. For claim 23, Astrom teaches selectively pausing a data stream (an IPTV broadcast) in response to an incoming call, using a "Time-Shift functionality" to record the content while the user takes the call.
    • Motivation to Combine: A POSITA would combine Astrom with the Widegren references to add a valuable and common feature—pausing media for an incoming call—to the session management system. Petitioner noted all references are assigned to Ericsson and relate to improvements in IP multimedia services, making the combination natural. Adding a pause function is an obvious improvement to provide better user control in a video streaming application.
    • Expectation of Success: The combination was asserted to be predictable, as it involves applying a known feature (pausing for a call) to a standardized IMS system, which is precisely what Astrom teaches.

4. Key Claim Construction Positions

  • Petitioner stated that for the purposes of the proceeding, it adopts the claim constructions for three key terms previously adopted by the Board in a Final Written Decision for the same patent (Ericsson FWD, IPR2022-00557):
    • "associated sessions": "sessions that should not be managed independent from each other"
    • "composition session": "a separate signaling session for managing the associated sessions that is initiated using a different signaling session than the associated sessions"
    • "exchanging the composition session identifier": "sending the composition session identifier in either direction"

5. Arguments Regarding Discretionary Denial

  • Petitioner presented several arguments that the Board should not exercise its discretion to deny institution.
    • Fintiv: Petitioner argued that discretionary denial under Fintiv is unwarranted because there is no parallel district court litigation concerning the validity of the ’669 patent between the parties.
    • §314(a): Petitioner contended that this petition is not an improper follow-on to the earlier Ericsson IPR because it is filed by a different petitioner, challenges a different set of claims, and is based on different prior art combinations.
    • §325(d): Petitioner asserted that the primary prior art (Widegren and Widegren-793) was never presented to or considered by the Examiner during prosecution. While Astrom and ETSI were cited in an IDS, the Examiner did not rely on them in any rejection, and the arguments presented in the petition based on these references are substantively different from what the Examiner considered.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 2-9, 13-18, 20, and 23 of the ’669 patent as unpatentable.