PTAB

IPR2026-00054

Disney Entertainment & Sports LLC v. Adeia Guides Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dynamic Media Streaming with Customized Manifests
  • Brief Description: The ’639 patent relates to techniques for chunk-based media streaming, specifically for dynamically creating manifest files. The technology addresses transitions between different media sources (e.g., primary content and advertisements) by rewriting timestamps to ensure seamless, continuous playback for the end-user on various device types.

3. Grounds for Unpatentability

Ground 1: Claims 8 and 13 are obvious over Lewis in view of Barraclough.

  • Prior Art Relied Upon: Lewis (Patent 8,677,428) and Barraclough (Patent 9,047,235).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lewis teaches a method for rule-based, dynamic server-side generation of streaming manifest files tailored to different client devices. Lewis discloses receiving a request from a first client (e.g., using a Flash Player plugin) and a second client (e.g., using an HLS client), determining the device type for each, and generating a first and second manifest, respectively, using different chunking protocols. Barraclough was asserted to supply the limitation of determining device type based on client identity by retrieving stored user-specific data, such as a "device classification" associated with an authenticated user.
    • Motivation to Combine: A POSITA would combine the references to improve the device targeting in Lewis's system using the stored user profiles taught by Barraclough. Petitioner contended that Lewis solves how to package a stream (dynamic manifest generation), while Barraclough solves what to deliver (the appropriate media version based on stored user data), making their combination a complementary and logical integration to achieve more precise user and device targeting.
    • Expectation of Success: Petitioner argued that since both references describe well-understood methods for customizing streamed media based on device type, their combination would have been predictable and presented a high expectation of success.

Ground 2: Claims 14 and 15 are obvious over Lewis-Barraclough in view of Jain.

  • Prior Art Relied Upon: Lewis (Patent 8,677,428), Barraclough (Patent 9,047,235), and Jain (Application # 2010/268573).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Lewis-Barraclough combination to address the "beaconing URL" limitations of dependent claims 14 and 15. Petitioner asserted that while Lewis teaches inserting advertisements at specific time blocks, it does not specify the signaling mechanism. Jain was cited for its teaching of an audio beaconing system that uses URLs to signal and track playback events, such as when an advertisement is served ("event beacon" with advertisement URL data) or when a video concludes ("video end beacon").
    • Motivation to Combine: A POSITA would implement Lewis's advertisement insertion feature using the known and cost-effective beaconing URL method taught by Jain. Because Lewis's manifest file already contains URLs for media segments, Petitioner argued it would have been an obvious design choice to add another URL to function as a beacon for tracking ad playback, a key commercial objective in media streaming.
    • Expectation of Success: The combination involved applying a known tracking technology (Jain's beacons) to a known adaptive streaming system (Lewis's manifests), which would have been a straightforward implementation with predictable results.

Ground 3: Claim 8 is obvious over Pyle in view of Barraclough.

  • Prior Art Relied Upon: Pyle (Patent 8,782,268) and Barraclough (Patent 9,047,235).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Pyle as a primary reference teaching the dynamic composition of media for streaming to different client devices. Pyle discloses selecting a suitable manifest for a first client (e.g., an HD television) and a second client (e.g., a smart phone) based on device capabilities and user preferences. As with the Lewis combination, Barraclough was used to teach determining the client identity through user authentication and retrieving stored "device classification" data to select the appropriate media format.
    • Motivation to Combine: A POSITA would combine Pyle and Barraclough to enhance Pyle's preference-based manifest optimization with Barraclough's explicit method of using stored data linked to an authenticated user. This would provide a more robust system for tailoring content delivery.
    • Expectation of Success: The combination was asserted to be predictable, as it merges two systems that both aim to customize media delivery based on client characteristics and user data.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Lewis alone, Pyle alone, and combinations including Pyle and Jain, but relied on similar design modification theories.

4. Key Claim Construction Positions

  • "Chunking protocol" (Claim 8): Petitioner proposed this term means "a protocol that dynamically creates segments of media based on a request." This construction was argued to be important because the prior art references (Lewis and Pyle) teach established streaming protocols like HLS and SSTP, which function by creating and delivering media segments (chunks) in response to client requests, thereby meeting the claim limitation under this interpretation.
  • "At least one beaconing URL..." (Claims 14-15): While arguing the term was indefinite in co-pending litigation, Petitioner for this IPR adopted the Patent Owner’s apparent interpretation: "a URL is used to signal or track playback of the advertisement or requested media source." This construction is central to the obviousness arguments relying on Jain, which teaches using URLs as beacons to track such playback events.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 8 and 13-15 of the ’639 patent as unpatentable.