PTAB

IPR2025-00558

Samsung Electronics Co Ltd v. Anonymous Media Research Holdings LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Media Measurement Using Dynamic Sample Parameter Adjustment
  • Brief Description: The ’911 patent discloses systems and methods for media usage monitoring. The core technology involves receiving video data, dividing it into samples, and attempting to identify media content by adjusting sampling parameters for subsequent samples based on the results of prior identification attempts.

3. Grounds for Unpatentability

Petitioner asserted two primary grounds that rely on a common combination of prior art. The arguments are presented collectively as the specifications of the primary references, Steuer750 and Steuer389, are substantively identical.

Ground 1 & 2: Obviousness over Steuer/Eldering - Claims 1-17 are obvious over Steuer750 or Steuer389 in view of Eldering.

  • Prior Art Relied Upon: Steuer750 (Application # 2005/0267750), Steuer389 (Patent 8,677,389), and Eldering (Application # 2006/0195860).
  • Core Argument for these Grounds:
    • Prior Art Mapping: Petitioner argued that the Steuer references (Steuer750 and Steuer389) teach nearly every element of the challenged claims but in the context of audio data rather than video data. Steuer discloses a media measurement method that receives audio data divisible into samples from a monitoring device. Critically, Steuer teaches adjusting sampling parameters for subsequent samples based on prior identification results. For example, Steuer discloses adjusting a "sample time window" (claim 1) and initiating "back track analysis" to select an intervening sample if identification results do not match (claim 11). Eldering, which operates in the same technical field of media content identification, explicitly discloses a system that identifies media content by matching samples of consumed media with a content database, and teaches that the incoming content can be either video or audio data. Petitioner contended that combining these references renders the challenged claims obvious by substituting the known use of video data (from Eldering) for the audio data in Steuer’s otherwise identical media measurement framework.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine the teachings because Steuer and Eldering address the same problem of media content identification. Eldering’s disclosure of using video data samples presented a known, suitable alternative to the audio-based approach in Steuer. A POSITA seeking to apply Steuer’s dynamic sampling method to video content—a common media format—would have been motivated to incorporate Eldering’s teachings on video sampling to achieve a predictable result.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in making this combination. The substitution involved applying a known technique (video sampling from Eldering) to a known system (Steuer's dynamic adjustment method), which would have yielded the predictable result of a video-based media measurement system.

4. Key Technical Contentions (Beyond Claim Construction)

  • Lack of Priority Claim / Effective Filing Date: A central contention of the petition is that the ’911 patent is not entitled to its claimed priority date, which extends back to a 2004 provisional application. Petitioner argued that the entire priority chain, up until a 2019 application, exclusively discloses and enables an audio-based measurement system. The key claim limitations requiring the use of "video data" and "video data samples" allegedly lack written description support in the earlier applications. Petitioner asserted that these priority documents focus entirely on audio fingerprinting and do not provide sufficient detail for a POSITA to understand that the inventors had possession of a video-based invention. Consequently, Petitioner argued the patent’s earliest effective filing date is May 3, 2019, making the asserted prior art references (Steuer750, Steuer389, and Eldering from 2005-2012) valid prior art under 35 U.S.C. §102(a)(1).

5. Arguments Regarding Discretionary Denial

  • Sotera Stipulation: The petition addressed the potential for discretionary denial under 35 U.S.C. §314(a) due to a parallel district court proceeding involving the ’911 patent. To preempt a denial based on Fintiv factors, Petitioner provided a Sotera stipulation, stating that if the inter partes review (IPR) is instituted, Petitioner will not pursue in the district court any invalidity ground that was raised or reasonably could have been raised in the IPR. Petitioner argued this stipulation mitigates any concerns about duplicative efforts and weighs strongly against discretionary denial.

6. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-17 of the ’911 patent as unpatentable.