PTAB

IPR2025-01103

Apple Inc v. Advanced Coding Technologies LLC

Key Events

Petition

petition

Title: Server Device for Media, Method for Controlling Server for Media, and Program
Brief Description: The ’101 patent discloses a server device for media capable of managing large amounts of digital content. The system features transferring content between an internal storage device and a network-connected storage device while providing a unified content list and managing transfers to prevent data loss from network failures.

Prior Art Relied Upon: Lamkin (Application # 2006/0161635).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Lamkin disclosed a "network media service" that meets the limitations of the challenged claims. Lamkin’s server device contained internal storage and connected to network storage devices. A "content management service" in Lamkin functioned as the claimed "transfer control unit," moving multimedia content between the server's internal storage and other network locations for centralization and archiving. Petitioner further contended that Lamkin's "content directory service" provided an aggregated list of all available content, regardless of its storage location, and organized files in a hierarchical folder system, thereby teaching the "tree structure" limitation. Lamkin also disclosed searching for and stream-delivering content to a network player.
- Key Aspects: For the limitation of not transferring content that would be unrecoverable in a network failure, Petitioner argued Lamkin rendered this obvious. Lamkin described not transferring certain content based on properties like large file size or DRM protections—conditions that a person of ordinary skill in the art (POSITA) would understand increase the risk of an unrecoverable transfer failure over an unreliable network.

Prior Art Relied Upon: Lamkin (Application # 2006/0161635), Fiechter (Patent 7,219,123).
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that to the extent Lamkin was viewed as not explicitly teaching how to handle potential network failures, Fiechter supplied the missing disclosure. Fiechter described a system for mobile devices that detected and compensated for data transmission errors over unreliable wireless networks. It explicitly taught detecting a high incidence of data loss and providing a user with options, such as waiting for a more reliable connection or proceeding with the transfer.
- Motivation to Combine: Petitioner argued a POSITA would combine Lamkin's media management system with Fiechter's explicit error-handling techniques to solve the known problem of unreliable network transfers. Improving the user experience and data integrity of Lamkin’s system by incorporating Fiechter's well-understood methods for managing poor connectivity would have been a simple and logical design choice.
- Expectation of Success: A POSITA would have had a reasonable expectation of success, as the combination involved applying conventional network error-handling solutions to a known media distribution system to achieve the predictable result of enhanced reliability.

Prior Art Relied Upon: Franke (Application # 2003/0195924).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Franke disclosed a data sharing system comprising a "local proxy server" (the claimed server device) and a "central server" (the network storage device). The proxy server stored media data internally and transferred it to the central server. Critically, Petitioner argued that Franke taught that this transfer only occurred if the local proxy server was "enabled." A POSITA would have understood an "enabled" state to require a stable connection, meaning the system would not transfer data if the network connection failed. This, Petitioner contended, rendered obvious the limitation of not transferring content that cannot be recovered during a network failure. Franke also disclosed a user interface that listed all project data, whether on the proxy or central server, and organized it in an "exemplary folder hierarchy," meeting the tree structure limitation.
Additional Grounds: Petitioner asserted additional obviousness challenges based on Lamkin in view of Ito (WO 2006/073040), Franke in view of Fiechter, and Franke in view of Ito. These grounds relied on similar rationales, with Ito providing teachings on terminating data backups of copyright-protected content to prevent data loss during network failure.

Petitioner argued that discretionary denial is unwarranted. It stated its intent to utilize the bifurcated briefing process contemplated by the March 26, 2025 Stewart Memorandum to rebut any contentions for denial advanced by the Patent Owner.

Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of the ’101 patent as unpatentable.