PTAB

IPR2026-00051

Disney Entertainment & Sports LLC v. Adeia Media Holdings LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cloud Data Persistence System
  • Brief Description: The ’987 patent discloses a system for distributing, storing, and retrieving data in a cloud networking environment. It describes a hierarchical architecture comprising a central origin server communicatively coupled with cache servers, which are in turn coupled with application servers, to efficiently manage data objects that link to separately stored media assets.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dilley alone or in view of Menon - Claims 1-13

  • Prior Art Relied Upon: Dilley (Application # 2007/0055764) and Menon (Application # 2002/0152318).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dilley taught a tiered "tiered distribution service" in a Content Delivery Network (CDN) that disclosed all key elements of the challenged claims. Dilley’s architecture included an "origin server" (the claimed first server), "parent server regions" (the claimed second and third cache servers), and "edge server regions" (the claimed application servers). Petitioner asserted that Dilley’s "object-specific metadata," used to manage content requests and comprising information like URLs and control parameters, corresponded to the ’987 patent’s "data objects." For claim limitations requiring media assets to be stored at a separate location from the data objects, Petitioner contended this was taught by Dilley’s disclosure of storing content in caches on edge/parent servers, which are geographically separate from the origin server. To the extent this separation was not explicit enough, Petitioner argued Menon taught storing metadata in a dedicated directory server separate from the content's origin server.
    • Motivation to Combine (for §103 grounds): Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Dilley with Menon to improve the efficiency of a CDN. Both references addressed efficient media distribution. A POSITA seeking to reduce bandwidth usage and load on Dilley's origin server—a known goal in the art—would have looked to Menon's explicit teaching of storing metadata on a separate directory server to further separate the management of metadata from the storage of the actual media content.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in combining the references, as both operated in the same technical field of tiered CDNs and employed well-understood, predictable networking technologies for distributing media content.

Ground 2: Obviousness over Russell alone or in view of Menon - Claims 1-13

  • Prior Art Relied Upon: Russell (Application # 2002/0069420) and Menon (Application # 2002/0152318).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Russell disclosed a content delivery network with a three-layer architecture that mapped directly to the server hierarchy of the ’987 patent’s claims. Russell’s "main server" was alleged to be the claimed first server, its "parent servers" were the claimed cache servers, and its "edge servers" were the claimed application servers. Petitioner contended that the "instructions" Russell’s main server published to other servers (e.g., an XML document listing content items and restrictions) functioned as the claimed "data objects," as they were metadata that provided information about the content and controlled its distribution. Petitioner further argued that Russell taught storing media assets (content) at a separate location, such as a "source server" that supplied the main server, or at the parent and edge servers, all of which are distinct from the main server where the "instructions" originate.
    • Motivation to Combine (for §103 grounds): Petitioner argued a POSITA would have been motivated to implement Russell’s "instructions" using the more explicit metadata teachings of Menon. Since metadata was a known mechanism for enabling intelligent decisions in content distribution, a POSITA would have incorporated Menon's teachings—such as using URLs within the metadata to link to content—into Russell’s system to enhance its functionality. This would make locating and accessing web resources simpler and more efficient.
    • Expectation of Success (for §103 grounds): A POSITA would have expected success in this combination because both references described methods for efficient media distribution in a tiered server network. Combining Russell’s architecture with Menon’s specific metadata implementation involved applying known and predictable technologies to achieve the recognized goal of improved performance.

4. Key Claim Construction Positions

  • "Data object" (Claims 1, 3-13): Petitioner identified differing constructions proposed in related litigation but argued that there was no meaningful difference between them for the purposes of the IPR. Petitioner contended the prior art taught the limitation under either party’s proposed construction, whether it is "metadata about a particular media asset, distinct from the asset itself" or a "data structure that contains information about a media asset."
  • "Data persistence cache servers" (Claim 7): Petitioner noted it had proposed this term was indefinite in related litigation. For the purposes of the petition, however, Petitioner interpreted the term to mean that the "third and second servers are cache servers," consistent with their function as described in the ’987 patent and mapped from the prior art.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of the ’987 patent as unpatentable.