PTAB

IPR2025-01403

Google LLC v. Art Research Technology LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus to Create and Save Annotations Associated with a Playable Media File
  • Brief Description: The ’840 patent discloses methods and systems for creating, saving, and associating annotations with playable media files like videos. The system allows users to add annotations, which are then organized into a table of contents associated with the media file.

3. Grounds for Unpatentability

Ground 1: Obviousness over Datar and Zhou - Claims 1, 3, 5-12, 14, 16-23, 25, and 27-33 are obvious over Datar in view of Zhou.

  • Prior Art Relied Upon: Datar (Application # 2008/0154908) and Zhou (a 2004 conference paper titled “A Web-Enabled Video Indexing System”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Datar teaches a system for transferring annotations associated with a media file, disclosing nearly all limitations of the independent claims. Datar describes users creating annotations for videos and submitting them to a network server, including a data profile with location information. However, Petitioner contended Datar does not explicitly teach creating a "table of contents" for these annotations. Zhou was argued to supply this missing element, as it describes a video indexing system that, for each video file, generates a "table-of-contents indexing file" used for previewing and browsing video content online.
    • Motivation to Combine: Petitioner asserted that Datar teaches indexing annotations but suggests the implementation is within the skill of a person of ordinary skill in the art (POSITA). A POSITA, seeking to implement Datar’s indexing function, would combine its system with Zhou’s explicit teaching of a table of contents. This combination represents the use of a known technique (a table of contents) for its intended purpose (organizing indexed data) to achieve a predictable result. The motivation is further supported by the need for consistent indexing to enable a collaborative community, a stated goal of Datar.
    • Expectation of Success: A POSITA would have had a high expectation of success because using a table of contents, such as the SMIL-based file in Zhou, to structure and index media content was a well-known and straightforward method in the art.

Ground 2: Obviousness over Datar, Zhou, and Gupta - Claims 2, 4, 13, 15, 24, and 26 are obvious over Datar in view of Zhou, further in view of Gupta.

  • Prior Art Relied Upon: Datar (Application # 2008/0154908), Zhou (a 2004 conference paper), and Gupta (Patent 7,051,275).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Datar and Zhou combination to address dependent claims requiring the initiation of a "discussion thread." Petitioner argued that while Datar describes a "collaborative community" of annotation authors, it does not explicitly mention discussion threads. Gupta was asserted to teach an annotation system where users can respond to other users' annotations, allowing "threads of discussion" composed of related annotations to develop.
    • Motivation to Combine: A POSITA would combine Gupta’s discussion thread functionality into the Datar/Zhou system to enhance the collaborative features already central to Datar's purpose. Facilitating user interaction through threaded discussions is a natural and obvious improvement for a collaborative annotation platform.
    • Expectation of Success: Incorporating threaded discussions into a networked annotation system was a standard programming task. A POSITA would have expected success in adding this feature to facilitate collaboration, as taught by Gupta.

Ground 3: Obviousness over Friedlander and Mouilleseaux - Claims 1-33 are obvious over Friedlander in view of Mouilleseaux.

  • Prior Art Relied Upon: Friedlander (Application # 2013/0145248) and Mouilleseaux (Application # 2009/0327856).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented this as an alternative invalidity theory. Friedlander was argued to teach a system allowing users in a social network to create and store comments (annotations) associated with video files, including transmitting comment data to a server. However, Friedlander is not specific about the data storage method. Mouilleseaux allegedly remedies this by describing various ways to store annotation data, including in a separate file containing data structures for multiple annotations, which Petitioner equated to a table of contents. Mouilleseaux teaches that this file can store start/end times and content for each annotation.
    • Motivation to Combine: A POSITA implementing Friedlander’s social commenting system would have required a method for storing the comment data. Mouilleseaux provides a finite number of predictable and suitable options for such storage. Petitioner argued a POSITA would have been motivated to use Mouilleseaux’s separate-file storage method because it advantageously allows the original video file to remain intact while annotations can be edited and transmitted separately.
    • Expectation of Success: Combining Friedlander's system with Mouilleseaux's known data storage methods would have been a routine integration task. A POSITA would have reasonably expected success in using a structured file, as taught by Mouilleseaux, to store the comment data generated in Friedlander's system.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 3) against claims 2-4, 6-11, 13-15, 17-22, 24-26, and 28-33 over Datar, Zhou, and Gupta, further in view of Smith (Patent 8,706,685). Smith was introduced to teach embedding annotations within the media data file itself, as an alternative to storing them separately.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-33 of the ’840 patent as unpatentable.