PTAB

IPR2025-01311

Samsung Electronics America Inc v. Maxell Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Digital Content Reproducing Apparatus
  • Brief Description: The ’091 patent describes a digital content reproducing apparatus, such as a set-top box, that displays digital content along with one of two distinct types of operation panels. A "linear" operation panel provides standard playback controls (e.g., play, pause), while an "interactive" operation panel provides functions that interact with an outside server (e.g., content menus, purchasing options).

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-5, 7, 11-15, 17, and 20 are obvious over Phillips in view of Wallis.

  • Prior Art Relied Upon: Phillips (Patent 7,293,276) and Wallis (Application # 2005/0188408).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Phillips discloses the core components of claim 1: a digital content apparatus with a controller that alternatively displays a first operation panel with linear buttons (e.g., a playback toolbar) and a second operation panel with interactive buttons (e.g., a Video-on-Demand (VoD) menu). However, Petitioner asserted Phillips lacks the claimed "related information" used to decide which panel to show. Petitioner contended that Wallis supplies this missing element by teaching a system that uses metadata ("panel related information") with associated attributes to govern the presentation of navigation controls. For example, Wallis’s "video controllable" attribute determines whether linear playback buttons are active, while attributes like "can save to favourites" or "target" determine whether interactive buttons are displayed.
    • Motivation to Combine: A POSITA would combine Wallis's metadata-driven control with Phillips's system to provide a more customized, flexible, and future-proof user experience. This combination would allow the system to dynamically populate operation panels with appropriate controls based on attributes delivered with the digital content, rather than relying on hard-coded panels for specific types of content screens as in Phillips. This provides a clear benefit of improved functionality and adaptability.
    • Expectation of Success: Petitioner asserted that integrating Wallis’s attribute table into Phillips would be a straightforward application of well-known programming techniques. The decision of which panel to display would be a predictable outcome of a simple conditional "if" statement based on the metadata attributes, a task well within the capabilities of a POSITA.

Ground 2: Claims 2, 6, 10, and 16 are obvious over the Phillips-Wallis combination in view of Uchida.

  • Prior Art Relied Upon: Phillips (Patent 7,293,276), Wallis (Application # 2005/0188408), and Uchida (Patent 8,773,360).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets dependent claims requiring the operation panels to be displayed in the "substantially same panel rendering area" (claim 2) and for the system to maintain the "rendering area size of the reproduced digital contents" when a panel is displayed (claims 6 and 16). Petitioner argued that while Phillips overlays its operation panels on top of the video content (which can obstruct the view or require resizing the content), Uchida explicitly addresses this problem. Uchida teaches a display methodology that divides the screen into a dedicated content display area and a separate, dedicated control panel area. This design inherently ensures that the control panels appear in the same location and that the content area size remains constant, regardless of which control panel is shown.
    • Motivation to Combine: A POSITA would be motivated to incorporate Uchida’s split-screen design into the Phillips-Wallis system to achieve the known benefits of a non-overlapping, tiled user interface. This modification would enhance the user experience by providing graphical consistency and ensuring that the operation panels never obstruct the digital content, a primary goal of effective GUI design.
    • Expectation of Success: The proposed modification would be simple and predictable. It would only require setting the position and size of the content and panel display areas according to Uchida's clear teachings, a trivial task for a POSITA that simply modifies the layout without altering the core functionality of the Phillips-Wallis system.

Ground 3: Claims 8, 9, 18, and 19 are obvious over the Phillips-Wallis combination in view of Ellis.

  • Prior Art Relied Upon: Phillips (Patent 7,293,276), Wallis (Application # 2005/0188408), and Ellis (Application # 2004/0154040).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets claims requiring the "time related information" to be an "appreciation term" corresponding to the content and related to a "predetermined date." The ’091 patent describes this as a limited period during which a user would be interested in content (e.g., news reports). Petitioner argued that Ellis discloses this exact concept by teaching an interactive television system where a program is available for a predetermined limited time (e.g., an episode of a show is available "only until 8:00PM Friday, after which it will expire"). This limited availability window is the claimed "appreciation term," and the expiration date constitutes the "predetermined date," during which interactive buttons are displayed for the user.
    • Motivation to Combine: A POSITA would combine Ellis’s concept of content expiration dates with the Phillips-Wallis system as a natural extension to manage time-sensitive content and improve e-commerce functionalities. Since Phillips already includes mechanisms for tracking time (e.g., for removing inactive on-screen panels), a POSITA would find it a modest technical modification to extend this time-tracking capability to manage program availability as taught by Ellis.
    • Expectation of Success: Petitioner argued for a high expectation of success, noting that the Ellis and Phillips systems are highly analogous and even share identical portions of their respective specifications and figures. The combination represents a simple substitution of known elements to achieve the predictable result of adding content expiration functionality.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds that add Logan (Application # 2012/0087637) to the Phillips-Wallis combination to further support the "time related information" limitations, and a separate ground alleging claims 1-3, 6-9 and 14-19 are obvious over Ellis’430 (Application # 2002/0174430) in view of Wallis.

4. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-20 of the ’091 patent as unpatentable.