PTAB

IPR2025-01405

Google LLC v. Art Research Technology LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System to Make and Display a Composite Virtual Clip
  • Brief Description: The ’103 patent describes methods for creating and displaying a "composite virtual clip" assembled from separate media clips. The core claimed invention involves using pseudocode that combines a programming loop structure with a system that uses pointers or links to identify the individual media clips comprising the composite clip.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hedinsson and Ford - Claims 1-10 and 13-22 are obvious over Hedinsson in view of Ford.

  • Prior Art Relied Upon: Hedinsson (Patent 8,793,282) and Ford ("Programming for the Absolute Beginner," a 2007 book).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hedinsson disclosed the fundamental structure of the claimed "composite virtual clip." Hedinsson taught creating a "playlist" composed of multiple "metadata clips," where each metadata clip acts as a pointer (containing a URL, start time, and end time) to a segment of a saved source media file. This structure, which allows for sequential streaming of different media segments without creating a new media file, allegedly met the claim limitations for a composite virtual clip defined by pointers to saved virtual clips. Petitioner asserted that Ford, a basic programming textbook, taught the well-known "do-until" programming loop. This loop structure directly mapped onto the claimed method steps for processing the clips: initializing a counter variable (M=1), repeatedly configuring a pointer for the M-th clip, saving the pointer, incrementing the counter (M=M+1), and repeating until the counter (M) equals the total number of clips (N).
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would be motivated to implement Hedinsson’s playlist creation and playback functions using a standard programming loop as taught by Ford. Using a loop was a well-known, fundamental programming technique to perform repetitive steps, which would reduce redundant code, improve efficiency, and allow the system to handle playlists with a variable number of clips, as contemplated by Hedinsson.
    • Expectation of Success: A POSITA would have had a high expectation of success because combining a known data structure (Hedinsson's playlist) with a basic, predictable programming construct (Ford's do-until loop) was a routine and straightforward implementation task.

Ground 2: Obviousness over Hedinsson, Ford, and Kostello - Claims 11-12 and 23-24 are obvious over Hedinsson in view of Ford and Kostello.

  • Prior Art Relied Upon: Hedinsson (Patent 8,793,282), Ford (a 2007 book), and Kostello (Patent 8,745,500).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Hedinsson and Ford from Ground 1 to address claims reciting the addition of visual effects. Petitioner argued that while Hedinsson mentioned the possibility of applying effects like "transition effects" and "image overlays," it provided minimal detail on how a user could select and apply different effects to different clips. Kostello allegedly supplied these missing details. Kostello disclosed a graphical user interface that allowed a user to select specific transition effects (e.g., cross-dissolve) to apply between consecutive video clips and different image effects (e.g., half-speed playback, color changes) for individual clips. Petitioner argued that it would have been obvious to add Kostello’s functionality for applying user-selectable, clip-specific effects to the base system of Hedinsson and Ford. The claimed pseudocode for recursively adding effect links or transition effect links using a do-until loop was merely the application of Ford's looping concept to the effect-adding functionality taught by Kostello.
    • Motivation to Combine: A POSITA seeking to implement the effects functionality suggested by Hedinsson would have been motivated to consult a reference like Kostello, which addressed the same technical field. The motivation was to provide users with greater creative flexibility and control over the final presentation, a recognized goal in video editing. Combining Kostello’s teachings would allow for different effects to be applied to different clips within a single playlist, enhancing the system described by Hedinsson.
    • Expectation of Success: There was a reasonable expectation of success in this combination. The use of transition and image effects was well-known and predictable in the art. Integrating Kostello's method for selecting and applying these known effects into the playlist structure of Hedinsson using the looping logic from Ford was presented as a combination of known elements for their intended purposes.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of the ’103 patent as unpatentable.