PTAB

IPR2025-01222

Amazon.com Inc v. DivX LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Progressive Video Playback System
  • Brief Description: The ’141 patent is directed to a progressive video playback system that supports trick play operations (e.g., seek, fast-forward, rewind). The system uses index information referencing data within a media file to allow a playback device to request specific byte ranges from a remote server, enabling non-linear playback.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hagai and Li - Claims 1, 3-8, 10, 20, 22-27, and 29 are obvious over Hagai in view of Li.

  • Prior Art Relied Upon: Hagai (Patent 7,051,110) and Li (Patent 8,731,369).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hagai disclosed the foundational client-server streaming system, including a playback device that communicates with a server via HTTP. Hagai’s system uses a “playback start position table” as index information to request specific byte ranges of media data, enabling seeking and playback from arbitrary points. Petitioner asserted that Li supplemented Hagai by teaching a multimedia file structure (RIFF) using metadata “chunks” to describe multiple available audio and subtitle tracks. Li further disclosed the use of DRM chunks and headers to manage encrypted content, including identifying decryption keys.
    • Motivation to Combine: A POSITA would combine Li's detailed metadata management for multiple tracks (audio, subtitle) and DRM with Hagai's foundational streaming framework. This combination would predictably result in a more feature-rich playback experience—a well-known objective in the art—by enabling track selection and playback of protected content within Hagai's seeking-capable system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved integrating known metadata structures into a conventional streaming architecture. The modification was straightforward and aimed at achieving the predictable result of enhanced functionality.

Ground 2: Obviousness over Hagai, Li, and Park - Claims 9, 12-14, 16-18, and 28 are obvious over Hagai and Li in view of Park.

  • Prior Art Relied Upon: Hagai (Patent 7,051,110), Li (Patent 8,731,369), and Park (Application # 2005/0198681).
  • Core Argument for this Ground:
    • Prior Art Mapping: Building on the Hagai and Li combination, Petitioner argued that Park disclosed the claimed step of "discarding audio and video data contained within the buffer in response to a received seek instruction." Park teaches a method of "playout buffer management" that explicitly flushes the buffer of residual or outdated data after a user command, such as a fast-forward or seek, to minimize latency and avoid playing stale content.
    • Motivation to Combine: A POSITA would be motivated to add Park's buffer-flushing technique to the Hagai-Li system to improve playback responsiveness and efficiency. Since Hagai’s system already included a buffer and buffer management, incorporating Park’s well-known technique for clearing outdated data upon a seek instruction would be a simple and logical improvement to minimize playout delays.
    • Expectation of Success: The combination would yield predictable results, as it involved applying a conventional buffer management solution to an existing playback system to solve the known problem of latency after trick play operations.

Ground 3: Obviousness over Hagai, Li, and Schmitz - Claims 2, 11, 21, and 30 are obvious over Hagai and Li in view of Schmitz.

  • Prior Art Relied Upon: Hagai (Patent 7,051,110), Li (Patent 8,731,369), and Schmitz (Patent 5,544,318).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Schmitz supplied key teachings for request management not found in the Hagai-Li combination. Specifically, Schmitz disclosed using asynchronous requests to enable arbitrary, non-linear navigation without waiting for prior requests to complete (mapping to claim 2). Schmitz also taught a "media server request mechanism" that permits the cancellation of outstanding queued requests that become obsolete when a user navigates to a new location, which Petitioner equated with "flushing previous byte range requests" (mapping to claim 11).
    • Motivation to Combine: A POSITA would incorporate Schmitz’s request management techniques into the Hagai-Li system to optimize client-server communication. Implementing asynchronous requests and flushing obsolete requests are known methods to improve system responsiveness, reduce server load, and enhance the user experience, aligning with the goals of the Hagai-Li streaming system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in implementing these modifications. The HTTP protocol used in Hagai is extensible, and modifying it to handle asynchronous requests or flush pending messages was a known technique for improving network application performance.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 15 and 19 based on the combination of Hagai, Li, Park, and Schmitz, relying on similar motivations to combine the teachings for improved playback performance and responsiveness.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’141 patent as unpatentable.