PTAB

IPR2025-01404

Google LLC v. Art Research Technology LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method to Annotate Playable Media Files in a Social Network
  • Brief Description: The ’001 patent discloses methods and systems for annotating playable media files, like videos, within a social network. The invention focuses on creating, storing, and displaying annotations, including the generation of a table of contents for these annotations.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 8-11, and 15-18 are obvious over Datar in view of Zhou and Smith

  • Prior Art Relied Upon: Datar (Application # 2008/0154908), Zhou (a 2004 conference paper), and Smith (Patent 8,706,685).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Datar teaches a collaborative system for creating and sharing annotations for media files, where annotations are "indexed" to specific instances of video. However, Datar does not specify the method of indexing. Petitioner asserted that Zhou, which describes a "web-enabled video indexing system," explicitly teaches generating a "table-of-contents indexing file" for each video to allow users to browse and jump to specific locations. This supplies the missing detail for Datar’s indexing. Furthermore, to the extent the claims require annotations to be "embedded" within the media file, Petitioner argued that Smith explicitly teaches this as a storage option, stating annotations can be stored separately or "embedded in a data file of the digital item."
    • Motivation to Combine: A POSITA implementing Datar's annotation indexing would combine it with Zhou’s table of contents because it is a straightforward and well-known method for organizing indexed data, improving the usability of Datar’s system. A POSITA would further be motivated to add Smith’s teaching of embedding annotations to simplify the transfer and playback of annotated media, a predictable design choice that avoids synchronization issues inherent in managing separate files.
    • Expectation of Success: Petitioner contended that a POSITA would have had a high expectation of success, as combining these known elements—a collaborative annotation system (Datar), a table of contents for indexing (Zhou), and an embedded storage option (Smith)—involved standard programming techniques to achieve predictable results.

Ground 2: Claims 5-7, 12-14, and 19-21 are obvious over Datar, Zhou, and Smith, further in view of Gupta

  • Prior Art Relied Upon: Datar (Application # 2008/0154908), Zhou (a 2004 conference paper), Smith (Patent 8,706,685), and Gupta (Patent 7,051,275).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address dependent claims reciting "discussion threads." Petitioner argued that the base combination of Datar, Zhou, and Smith provides a complete system for creating, indexing, and storing annotations. Gupta was introduced because it explicitly teaches an annotation system where users can respond to other users’ annotations, such that "threads of discussion can develop." This directly addresses the limitations of the challenged dependent claims.
    • Motivation to Combine: Since Datar and Smith already teach collaborative annotation environments, a POSITA would combine their teachings with Gupta's discussion threads to enhance collaboration. Allowing users to reply directly to comments is a logical and desirable extension of a system designed for community interaction, facilitating more organized and contextual conversations around the media content.
    • Expectation of Success: Petitioner asserted that incorporating discussion threads into the base system would be a routine task for a POSITA. It would predictably be accomplished with standard programming, such as by adding data fields to link related annotations, and would have been expected to function as intended.

Ground 3: Claims 1-21 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 argued that Friedlander teaches a system for users in a social network to add time-coded comments to video files but does not specify the data storage method. Mouilleseaux remedies this by teaching several methods for storing annotation data, including two key options: 1) storing annotations in a separate file using a data structure that contains a reference to the media file, start/end times, and content, which functions as a table of contents; and 2) embedding the annotation data within the media file itself as metadata. The combination of Friedlander's social annotation system with Mouilleseaux's concrete storage methods allegedly renders all challenged claims obvious.
    • Motivation to Combine: A POSITA implementing Friedlander’s system would require a method to store the comment data. Mouilleseaux presented a finite number of suitable and predictable options. A POSITA would combine the two references to provide a functional backend for Friedlander’s system, choosing a storage method from Mouilleseaux based on desired outcomes, such as allowing annotations to be edited later or simplifying file distribution by embedding them.
    • Expectation of Success: Petitioner contended that selecting a storage architecture (Mouilleseaux) for an annotation system (Friedlander) was a routine design choice for a POSITA. The technologies were compatible and their combination was straightforward, leading to a high expectation of successfully creating a functional system with predictable results.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of Patent 9,451,001 as unpatentable.