PTAB

IPR2025-01223

Amazon.com Inc v. DivX LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Method for encoding source content for adaptive streaming
  • Brief Description: The ’785 patent discloses methods for encoding source video content into multiple alternative streams for adaptive bitrate streaming. The claimed invention involves encoding content at various resolution and bitrate combinations, evaluating the quality of these encodings, and selecting an optimal set of streams for delivery to a playback device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ozer and Liao - Claims 1-4, 7-14, and 17-19 are obvious over Ozer in view of Liao.

  • Prior Art Relied Upon: Ozer ("Video Compression for Flash, Apple Devices and HTML5," a 2011 publication) and Liao (Patent 9,832,540).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ozer taught the fundamental framework for adaptive bitrate streaming claimed in the ’785 patent. This included encoding a source video into multiple alternative streams with different pre-specified resolutions and bitrates, storing the chunked streams on a Content Delivery Network (CDN), and using a top-level index file (or "manifest file") to allow a playback device to request and switch between streams. However, Petitioner contended that Ozer only broadly discussed the "cost/quality trade-off" without teaching a specific method for optimizing it. Liao allegedly supplied this missing element by teaching a method to determine the appropriate bitrate for encodings while maintaining video quality. Specifically, Liao disclosed encoding a media program at multiple different target bitrates for a given resolution, evaluating the quality of each encoding using a Structural Similarity Index (SSIM), and selecting the lowest bitrate that achieves a minimum required quality level.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Ozer and Liao to optimize the known cost/quality trade-off inherent in adaptive streaming, as described by Ozer. Liao provided a specific, well-understood methodology (SSIM-based evaluation) to systematically select the most efficient bitrate for each resolution, thereby ensuring acceptable quality without expending unnecessary network resources on excessively high bitrates.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination merely involved applying Liao’s standard quality evaluation technique to determine the customizable encoder settings for the adaptive streaming system described in Ozer.

Ground 2: Obviousness over Ozer, Liao, and Gu - Claims 6 and 16 are obvious over Ozer in view of Liao and Gu.

  • Prior Art Relied Upon: Ozer, Liao, and Gu (Patent 8,396,114).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination of Ozer and Liao to address the limitations of claims 6 and 16, which require identifying resolutions with target bitrates that are "within a predetermined percentage" of a bitrate associated with an alternative stream. While Ozer identified the problem of needing a reasonable "gap" between bitrates in an encoding ladder (to avoid excessive switching or jarring quality jumps), it did not teach how to determine this gap. Gu allegedly disclosed a solution by teaching that target bitrates for alternative streams should "decrease progressively in a proportional, logarithmic or other decreasing manner." Gu provided a specific example of decreasing the bitrate of each successive stream proportionally by 25% from the highest selected bitrate.
    • Motivation to Combine: A POSITA, having combined Ozer and Liao, would be further motivated to incorporate Gu to solve the bitrate spacing problem identified in Ozer. Gu provided a concrete, predictable method (a predetermined percentage decrease) for establishing the reasonable "gap" between bitrates needed for an effective adaptive streaming experience.
    • Expectation of Success: A POSITA would have an expectation of success in implementing Gu’s well-known technique for proportional bitrate spacing into the Ozer/Liao framework to create a more robust and efficient bitrate ladder.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Ronca (Application # 2011/0246616) in view of Liao (Ground 3) and Ronca in view of Liao and Gu (Ground 4). These grounds relied on similar arguments, substituting Ronca for Ozer as the primary prior art reference disclosing a foundational adaptive streaming system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6-14, and 16-19 of the ’785 patent as unpatentable.