PTAB

IPR2025-01003

Amazon.com Inc v. Audio Pod IP LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Synchronizing Digital Media Streams
  • Brief Description: The ’907 patent describes methods for creating synchronized audiobooks by generating a descriptor file that coordinates multiple digital media streams, such as audio narration and text, derived from the same original work. This descriptor file contains timing and location information to enable synchronized rendering on a client device.

3. Grounds for Unpatentability

Ground 1: Claims 1-14, 17-19, and 21 are obvious over DTB

  • Prior Art Relied Upon: DTB (NATIONAL INFORMATION STANDARDS ORGANIZATION, SPECIFICATIONS FOR THE DIGITAL TALKING BOOK (ANSI/NISO Z39.86-2002)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that DTB, a standard for digital talking books for the visually impaired, discloses every limitation of the challenged claims. DTB explicitly teaches using an external Synchronized Multimedia Integration Language (SMIL) file as a descriptor file to synchronize audio, text, and image streams from an originating work (e.g., a print book). Petitioner asserted that DTB’s SMIL file stores location information for media streams via URIs, identifies time offsets using clipBegin and clipEnd attributes, corresponds these offsets to content points like paragraphs or headings within <par> elements, and stores this information in a correlated manner to allow synchronized playback on a client device (a DTB player). The arguments for dependent claims followed from this primary mapping, asserting DTB also discloses features like bookmarking (claims 4-6), automated page turns (claim 7), and discontinuous media streams (claim 19).
    • Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference.
    • Expectation of Success (for §103 grounds): Not applicable.

Ground 2: Claims 1-3, 8-12, 14, 17-19, and 21 are obvious over McCartney

  • Prior Art Relied Upon: McCartney (Application # 2003/0033147).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that McCartney teaches a method for constructing a digital talking book using synchronization files to coordinate text and audio data. McCartney discloses using two separate but related descriptor files: a Time Stamp Data (TSD) file and a Book Project Management (BPM) file. The TSD file contains time offsets (start/end times) correlated to content points (identified by unique IDs), while the BPM file contains location information for the text files and identifies synchronizable elements like headings. Petitioner argued these files collectively perform the functions of the claimed descriptor file.
    • Motivation to Combine (for §103 grounds): While McCartney uses two files, Petitioner argued a POSITA would find it obvious to combine their data into a single descriptor file to simplify management, access, and revision of the synchronization information.
    • Expectation of Success: A POSITA would have a high expectation of success in combining the files because McCartney discloses that both the TSD and BPM files can be processed by an XML application, indicating a compatible data format suitable for consolidation into a single file.

Ground 3: Claims 2, 18, and 19 are obvious over DTB in view of Yoshimura

  • Prior Art Relied Upon: DTB (a 2002 ANSI/NISO standard) and Yoshimura (a 2003 IEICE journal article).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the teachings of DTB by adding Yoshimura to address claims requiring server-side functionality. Claim 2 requires storing the descriptor file on a server, and claim 18 requires that some media content is not resident on the client device. Petitioner argued that while DTB provides the foundational synchronized media system, Yoshimura explicitly teaches a content delivery network where SMIL files are stored on and downloaded from a portal server to a mobile client. This enables streaming and retrieval of media content that is not stored locally on the client device.
    • Motivation to Combine: A POSITA would combine DTB's digital talking book system with Yoshimura’s server-based architecture to achieve well-known benefits. These include centralized management and version control of the descriptor files and an improved user experience by allowing access to a wide range of content without consuming limited local storage on the client device.
    • Expectation of Success: Success would be expected because both references use the same technology (SMIL files) for the same purpose (synchronizing multimedia). Applying Yoshimura’s known server-storage technique to DTB’s system was a predictable implementation choice for network-based content delivery.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, primarily by combining either DTB or McCartney with secondary references to teach specific dependent claim features. These combinations included DTB with Duncan (for automated page turns), DTB with Heckerman (for selecting time offsets based on natural language gaps), DTB with Bulterman (for embedding human-readable text), McCartney with Kauffman (for server storage), and McCartney with DTB (for bookmarking functionality).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of Patent 9,729,907 as unpatentable under 35 U.S.C. §103.