PTAB

IPR2026-00055

Disney Entertainment & Sports LLC v. Adeia Guides Inc

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1. Case Identification

2. Patent Overview

  • Title: Methods for Monitoring User Viewing Progress
  • Brief Description: The ’595 patent describes methods for monitoring and presenting a user's viewing progress across multiple serial media programs. The system creates a media profile to track progress and generates user-selectable links that allow the user to resume viewing from specific progress points.

3. Grounds for Unpatentability

Ground 1: Claims 1-5 are obvious over Tecot in view of Lee.

  • Prior Art Relied Upon: Tecot (Application # 2005/0097623) and Lee (Patent 7,127,735).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tecot disclosed the core functionality of the challenged claims. Tecot taught a system for bookmarking multimedia content, including multiple serial programs, to allow a user to resume viewing from the bookmarked position. Tecot’s graphical user interface (GUI) displayed a list of bookmarked programs, which functioned as user-selectable links to resume playback. Petitioner asserted that Lee supplied the remaining limitations by teaching a video-on-demand (VOD) system that stores a user’s viewing progress (an interrupted position) in a user-specific "media profile" on a local storage device. The combination of Tecot's multi-program bookmarking with Lee's concept of a stored media profile met the limitations of creating and storing a media profile containing viewing progress for first and second serial programs.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Tecot and Lee because both addressed the same problem of resuming media from an interrupted point. A POSITA would have been motivated to implement Tecot’s user-specific bookmarks within a formal user profile, as taught by Lee, to provide a more customized experience, differentiate between multiple users in a household, and reduce server load, which Lee explicitly identified as a benefit.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references described methods using similar, well-understood hardware and software components for interactive media systems.

Ground 2: Claims 1-5 are obvious over Logan in view of Poslinski.

  • Prior Art Relied Upon: Logan (Patent 5,732,216) and Poslinski (Application # 2006/0048184).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Logan taught a system for distributing serialized audio programs where a "session usage log" records the user's progress to allow resumption of playback. This usage log, which tracks progress across multiple "programs" in a session, constituted the claimed "media profile." Petitioner contended that Logan’s system included a display and the ability to select programs from a scrolling list. Poslinski was asserted to teach the visual and adjacent display of progress for multiple video programs. Poslinski disclosed displaying multiple, distinct progress bars (e.g., for a main and secondary program) one above the other, which a user could select. These selectable progress bars met the limitation for adjacent, user-selectable links corresponding to progress points in different serial programs.
    • Motivation to Combine: A POSITA would combine Logan’s progress tracking with Poslinski’s more advanced visual interface to enhance the user experience. Since Logan's system already had video display capabilities, it would have been a simple and predictable improvement to incorporate Poslinski’s graphical progress bars to visually represent the playback status of the serialized programs tracked by Logan. This would allow a user to flexibly view and manage multiple programs.
    • Expectation of Success: Success was expected as both references related to managing media playback and used conventional hardware. Integrating Poslinski's GUI elements into Logan's data-logging framework was a predictable combination of known technologies.

  • Additional Grounds: Petitioner asserted that claim 6 is obvious over the combination of Tecot and Lee in view of McElhatten (Application # 2003/0220100). McElhatten was cited for its teaching of a "Lookback" GUI that lists available episodes for a selected series by episode number, allegedly teaching the claim 6 limitation of a "summary region [that] indicates a predefined viewing order." A similar ground was raised making claim 6 obvious over the combination of Logan and Poslinski in view of McElhatten.

4. Key Claim Construction Positions

  • “[First/second] progress point” (Claim 1): Petitioner proposed this term means "the user’s time position within an episode." Petitioner argued there was no meaningful difference between its proposed construction and the Patent Owner's position of "plain and ordinary meaning" as applied to the prior art.
  • “Serial program” (Claims 1, 4-6): Petitioner proposed this term means "related programming containing a temporal component connecting episodes." This construction was argued to be consistent with the specification and broad enough to cover the serial content disclosed in the prior art.
  • “The summary region” (Claim 6): Petitioner noted that it has argued this term is indefinite in co-pending litigation. For the purposes of the IPR, Petitioner interpreted it to mean a summary region as recited in claim 5.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be improper, particularly regarding the grounds based on Logan. During the original prosecution of the ’595 patent, the Applicant submitted a sixteen-page Information Disclosure Statement (IDS) that included the Logan reference. The Examiner explicitly crossed out this entire IDS, indicating that Logan and the other 372 references therein were not considered. Petitioner contended this constituted a material error by the PTO, and therefore, the arguments based on Logan were not previously before the Office.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-6 of the ’595 patent as unpatentable.