PTAB

IPR2025-00504

Samsung Electronics America Inc v. Koninklijke KPN NV

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Gateway for Transmitting Multimedia Streams
  • Brief Description: The ’151 patent relates to gateways that manage multimedia streams between a first terminal and a second terminal using communication protocols like Session Initiation Protocol (SIP) and Real Time Streaming Protocol (RTSP). The patent’s purported improvement is a method where the gateway provides a "trigger" to the second terminal to initiate an exchange of media session information for setting up a media stream.

3. Grounds for Unpatentability

Ground 1: Obviousness over Alston and Fajardo

  • Claims 1-4, 7-10, and 12-18 are obvious over Alston in view of Fajardo.
    • Prior Art Relied Upon: Alston (Application # 2006/0271687) and Fajardo (Patent 8,068,460).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner argued that Alston disclosed a residential broadband gateway that uses standard SIP messages to establish media sessions between a first terminal (mobile device) and a second terminal (media delivery device). Alston’s gateway sending a "second invite message" to the second terminal was asserted to be the claimed "trigger." This trigger initiates a SIP-based exchange of media session information (via SIP INVITE and OK messages) that sets up the first and second media streams. For the limitation requiring a media server that buffers the stream (claim 1e), Petitioner contended that Fajardo explicitly taught using "playout buffers" in SIP and IP Multimedia Subsystem (IMS) systems to minimize packet loss and fix gaps in traffic, rendering the addition of this feature obvious.
      • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Fajardo’s buffering teachings with Alston’s streaming system to improve reliability and handle network jitter. Buffering was a well-known and necessary solution for ensuring seamless data stream handling in multimedia systems like the one described in Alston.
      • Expectation of Success: A POSITA would have a reasonable expectation of success because media buffering was a standard, widely implemented technique for multi-media content delivery in IMS/3GPP systems at the time.

Ground 2: Obviousness over Alston, Gateva, and Fajardo

  • Claims 1-18 and 22 are obvious over Alston in view of Gateva, with Fajardo cited for buffering.
    • Prior Art Relied Upon: Alston (Application # 2006/0271687), Gateva (Application # 2004/0184432), and Fajardo (Patent 8,068,460).
    • Core Argument for this Ground:
      • Prior Art Mapping: This ground built upon Alston’s disclosure of a gateway system by incorporating Gateva’s teachings on integrating SIP and RTSP. Petitioner argued that Gateva taught a method where a "DESCRIBE" message, sent using RTSP, acts as a trigger to an RTSP client. This trigger initiates an exchange of media session information via subsequent RTSP messages ("SETUP," "200 OK") to establish a media stream. This combination provides a specific implementation of the multi-protocol system claimed in the ’151 patent, where SIP is used for initial session setup (as in Alston) and RTSP is used for session control and media stream management (as in Gateva).
      • Motivation to Combine: A POSITA would combine Gateva’s SIP-RTSP messaging scheme with Alston’s gateway architecture to gain the benefits of both protocols. It was a known design choice to use SIP for its robust session initiation capabilities and RTSP for its fine-grained media playback controls (e.g., play, pause), thereby creating a more functional and interactive streaming service.
      • Expectation of Success: The combination was a straightforward design choice to address common interoperability requirements in multimedia streaming. A POSITA would expect success in integrating these widely used and compatible protocols within the known gateway architecture of Alston.

Ground 3: Obviousness over Mela, Alston, and Fajardo

  • Claims 1-5, 7-10, 12-20, and 22-23 are obvious over Mela alone, or in view of Alston and/or Fajardo.
    • Prior Art Relied Upon: Mela (Patent 7,724,691), Alston (Application # 2006/0271687), and Fajardo (Patent 8,068,460).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner asserted that Mela disclosed a gateway that maps between SIP and RTSP protocols. In Mela’s disclosed message flow, an RTSP "200 OK" message sent from the gateway to an RTSP client (second terminal) served as the claimed "trigger." This trigger prompts the RTSP client to initiate a "SETUP" message exchange with the gateway, which establishes the second media stream. Petitioner argued that Mela taught all elements of the independent claims, but cited Alston and Fajardo as evidence that adding media server and buffering functionality was an obvious modification to address well-known streaming challenges.
      • Motivation to Combine: A POSITA would be motivated to incorporate a media server with buffering capabilities, as taught by Alston and Fajardo, into Mela’s gateway system. This modification would enhance the reliability and quality of media delivery by compensating for network variability, jitter, and packet loss, which are common issues that buffering is known to solve.
      • Expectation of Success: A POSITA would expect this combination to succeed because adding a centralized buffering server was a known architectural improvement for RTSP-based systems. It was a predictable solution to enhance stream stability and user experience.

4. Arguments Regarding Discretionary Denial

  • Fintiv: Petitioner argued that discretionary denial under Fintiv is unwarranted because no parallel district court litigation involving a validity challenge exists between the parties. Therefore, factors 1-5 favor institution, and the petition's compelling merits (Factor 6) further weigh against denial.
  • §314(a): Denial under §314(a) was argued to be inappropriate as there have been no previous or current inter partes review (IPR) proceedings involving the ’151 patent.
  • §325(d): Petitioner contended that denial under §325(d) would be improper. For Grounds 1 and 2, the primary prior art references (Alston, Gateva, Fajardo) were not cited or considered by the Examiner during prosecution. For Ground 3, although Mela was previously considered, Petitioner asserted that it presented new, non-overlapping arguments based on different aspects of Mela’s disclosure and new combinations not before the Examiner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-23 of Patent 8,549,151 as unpatentable.