DuoDecad IT Services Luxembourg S.a r.l.v.WAG Acquisition, LLC

Patent Trial and Appeal Board

Oct 23, 2015

12800177 (P.T.A.B. Oct. 23, 2015)

Trials@uspto.gov Paper 8
571-272-7822 Entered: October 23, 2015

UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

DUODECAD IT SERVICES LUXEMBOURG S.À.R.L.,
FRIENDFINDER NETWORKS INC., AND STREAMRAY INC.,
Petitioners,

v.

WAG ACQUISITION, LLC,
Patent Owner.
_______________

Case IPR2015-01035
Patent No. 8,185,611 B2
____________

Before GLENN J. PERRY, TREVOR M. JEFFERSON,
BRIAN J. McNAMARA, Administrative Patent Judges.

JEFFERSON, Administrative Patent Judge.

DECISION
Denying Institution of Inter Partes Review
37 C.F.R. § 42.108

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I. INTRODUCTION
Duodecad IT Services Luxembourg S.à.r.l., Friendfinder Networks
Inc., and Streamray Inc. (collectively “Petitioner”) filed a Petition (Paper 2,
“Pet.”) to institute an inter partes review of claims 1–18 of U.S. Patent No.
8,185,611 B2 (Ex. 1001, “the ’611 patent”) pursuant to 35 U.S.C. § 311 et
seq. Patent Owner, WAG Acquisition, LLC (“WAG”), filed a Preliminary
Response to the Petition. Paper 6 (“Prelim. Resp.”). We have jurisdiction
under 35 U.S.C. § 314(a), which provides that an inter partes review may
not be instituted “unless . . . there is a reasonable likelihood that the
petitioner would prevail with respect to at least 1 of the claims challenged in
the petition.” After considering the Petition, the Preliminary Response, and
cited evidence, we conclude that Petitioner has not demonstrated a
reasonable likelihood that it would prevail in showing unpatentability of any
of the challenged claims.
A. Related Proceedings
Petitioner states that WAG has asserted the ’611 patent in eight
pending litigations: WAG Acquisition, LLC v. Sobonito Investments, Ltd.,
Case No. 2:14-cv-1661-ES-JAD (D.N.J.), WAG Acquisition, LLC v. Multi
Media, LLC, Case No. 2:14-cv-2340-ES-JAD (D.N.J.), WAG Acquisition,
LLC v. Data Conversions, Inc., Case No. 2:14-cv-2345-ES-JAD (D.N.J.),
WAG Acquisition, LLC v. Flying Crocodile, Inc., Case No. 2:14-cv-2674-
ES-MAH (D.N.J.), WAG Acquisition, LLC v. Gattyàn Group S.à.r.l., Case
No. 2:14-cv-2832-ES-JAD (D.N.J.), WAG Acquisition, LLC v. MFCXY, Inc.,
Case No. 2:14-cv-3196-ES-MAH (D.N.J.), WAG Acquisition, LLC v.
FriendFinder Networks Inc., Case No. 2:14-cv-3456-ES-JAD (D.N.J.); and
WAG Acquisition, LLC v. Vubeology, Inc., Case No. 2:14-cv-04531-ES-JAD
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(D.N.J.). Pet. 2.
Petitioner filed related petitions for inter partes reviews of U.S. Patent
No. 8,364,839, U.S. Patent No. 8,122,141 and U.S. Patent No. 8,327,011,
specifically IPR2015-01033 (U.S. Patent No. 8,327,011); IPR2015-01036
(U.S. Patent No. 8,364,839); and IPR2015-01037 (U.S. Patent No.
8,122,141).
B. The ʼ611 Patent
The ’611 patent discloses “systems and methods for delivering
streaming media, such as audio and video, on the Internet.” Ex. 1001, 1:30–
33. The ’611 patent states that “[t]here is a need for improved systems and
methods for delivering streaming content over the Internet . . . , which
facilitate continuous transmission of streaming content, respond on demand
without objectionable buffering delay, and perform without disruption or
dropouts.” Id. at 3:23–28. The ’611 patent addresses these objectives by
“(a) sending initial streaming media elements to the user system at a sending
rate more rapid than the playback rate, to fill the user playback buffer; and
(b) after the user buffer has been filled, sending further streaming media data
elements to the user system at about the playback rate.” Id. at 3:37–42.
Figure 1, below, illustrates one embodiment of the elements of the ’611
patent streaming media buffering system. Id. at 4:1–2.
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Figure 1 shows that server 12 has server buffer 14, a conventional computer
storage mechanism, for storing data elements for transmission, and buffer
manager 16. Id. at 6:12–20. Data elements may be from live source 26, or a
stored file on sever 12. Id. The ’611 patent discloses that “[t]here are a
large number of ways of managing server buffer 14 . . . to implement the
systems and methods described in [the] specification.” Id. at 6:59–61.
C. Illustrative Claim
Claim 1 is illustrative of the claims at issue and is reproduced below:
1. A method for distributing streaming media via a
data communications medium such as the Internet to at
least one user system of at least one user, the streaming
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media comprising a plurality of sequential media data
elements for a digitally encoded audio or video program,
the user system being assumed to have a user buffer for
receiving media data and facilities to play back the
streaming media at a playback rate for viewing or
listening by said at least one user, said method
comprising: sending initial streaming media elements to
the user system at an initial sending rate more rapid than
the playback rate, to fill the user buffer; and configuring
the initial streaming media elements so that the amount
of said initial elements, and said initial sending rate, are
sufficient for the user system to begin playing back the
streaming media while the user buffer continues to fill;
and after the user buffer has been filled, sending further
streaming media data elements to the user system at
about the playback rate; and wherein the media data
elements is sent at a rate that matches the constant fill
rate of a server buffer, and is received at the same rate by
the user computer if there are no interruptions in the
transmission of media data between the server and the
user's computer.
D. Alleged Grounds of Unpatentability
The Petition sets forth proposed grounds of unpatentability of claims
1–18 of the ’611 patent as follows (Pet. 3):
References Basis Claims Challenged
Chen1 and Chen FH2 35 U.S.C. § 103 1–18
Chen, Chen FH, and
Carmel3 35 U.S.C. § 103 1–18
Chen, Chen FH, Carmel,
and ISO-111724 35 U.S.C. § 103 1–18
1 U.S. Patent No. 5,822, 524, issued Oct. 13, 1998 (Ex. 1004, “Chen”).
2 File History of U.S. Application No. 08/505,488, which issued as U.S.
Patent No. 5,822,524 (Ex. 1005, “Chen FH”).
3 U.S. Patent No. 6,389,473 B1, issued May 14, 2002 (Ex. 1006, “Carmel”).
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II. ANALYSIS
A. Claim Interpretation
In an inter partes review, claim terms in an unexpired patent are given
their broadest reasonable construction in light of the specification of the
patent in which they appear. 37 C.F.R. § 42.100(b); see also In re Cuozzo
Speed Techs., LLC, 793 F.3d 1268, 1278–79 (Fed. Cir. 2015) (stating that
“Congress implicitly approved the broadest reasonable interpretation
standard in enacting the AIA,” and “the standard was properly adopted by
PTO regulation”) reh’g en banc denied, 793 F.3d 1297 (Fed. Cir. 2015).
Under the broadest reasonable construction standard, claim terms are given
their ordinary and customary meaning, as would be understood by one of
ordinary skill in the art in the context of the entire disclosure. In re
Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). Any special
definition for a claim term must be set forth with reasonable clarity,
deliberateness, and precision. In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir.
1994).
1. Claims 1, 3, 8, 9, 14, and 15—“playback rate”
Petitioner submits “playback rate” is “a rate at which the data is
encoded for playback to a user.” Pet. 12. Patent Owner does not dispute
Petitioner’s proposed construction, but notes that the ’611 patent “defines
the term ‘playback rate,’ with respect to ‘media data (whether real-time or
file based)’ as ‘the rate at which [such media] will be played out.’” Prelim.
Resp. 17 (quoting Ex. 1001, 5:37–40).
4 International Standard Reference number ISO/IEC 11172-1:1993(E) (Exs.
1007–1009, “ISO-11172”).
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For purposes of this Decision, we agree with Petitioner and construe
“playback rate” as “a rate at which the data is encoded for playback to a
user.”
2. Claims 1, 8, and 14—“at about playback rate”
Petitioner argues that “at about playback rate” is indefinite. Pet. 12.
If the claim phrase is not indefinite, Petitioner argues in the alternative that
the phrase should be construed to mean “any rate.” Id.
Patent Owner disagrees, arguing that the term is properly construed as
“at approximately the rate at which the media will be played out.” Prelim.
Resp. 16–18. The specification defines the term “playback rate,” with
respect to “media data (whether real-time or file based)” as “the rate at
which [such media] will be played out.” Ex. 1001, 5:37–40. The
specification also uses the term “about the playback rate.” Id. at 3:40–42.
The specification further states that its disclosures concern both constant bit
rate (CBR) and variable bit rate (VBR) encoded media. Id. at 4:33–35. The
specification then expressly states: “Statements in this specification
concerning ‘constant’ data rates and the like should be understood as subject
to appropriate variation where VBR-encoded data may be involved.” Id. at
4:47–50. Patent Owner argues that an ordinarily skilled practitioner would
understand that “about” the playback rate takes into account variations from
a constant data rate that may arise as a result of variable encoding. Prelim.
Resp. 17. We are persuaded by Patent Owner’s argument.
For purposes of this decision, we adopt Patent Owner’s proposed
construction.
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3. Claims 1, 3–5, 8, 9, 12, and 14–16—Preamble Claim Phrases
Petitioner argues that no patentable weight should be given to the
preamble phrase elements. Pet. 12–14. Petitioner argues that these phrases
are “merely an intended use and [do] not state any sort of functional or
structural limitation on the respective claim[s].” Id. at 13–14.
We need not reach this issue for purposes of this Decision. See Vivid
Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)
(“only those terms need be construed that are in controversy, and only to the
extent necessary to resolve the controversy”). Accordingly, we determine
that these preamble phrases do not require construction.
4. Claims 1, 3–5, 8, 9, 12, and 14–16— “configuring the initial streaming
media elements so that the amount of said initial elements, and said
initial sending rate, are sufficient for the user system to begin playing
back the streaming media while the user buffer continues to fill”
Because the ’611 patent and its prosecution history are silent as to
what qualifies as “sufficient for the user system to begin playing back the
streaming media while the user buffer continues to fill” (emphasis added) as
recited in claims 1, 3–5, 8, 9, 12, and 14–16, Petitioner contends that the
claims are indefinite. Pet. 14. To the extent the phrase is construed,
Petitioner assert that he broadest reasonable construction is “the initial
amount of streaming media data elements are sent at an initial sending rate
greater than the playback rate of the initial amount of streaming media data
elements.” Id. Patent Owner submits that the plain meaning of this
limitation is that enough data is initially sent fast enough so that the player
can at least get started with playback while its buffer continues to fill.
Prelim. Resp. 18 (citing Ex. 1001, 8:44–46).
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We are persuaded by Patent Owner that the plain meaning of the
claim phrase is applicable. Based on the record before us, we do not agree
with Petitioner that the claim phrase is indefinite. Instead, we determine that
the broadest reasonable interpretation of the claim phrase is that sufficient
data is sent such that the player can start playback while the buffer continues
to fill.
5. Claims 1, 3–5, 8, 9, 12, and 14–16—“constant fill rate of a server
buffer”
Petitioner argues again that the claim phrase “constant fill rate of a
server buffer” is not amenable to construction and is indefinite. Pet. 15. In
the alternative, Petitioner asserts that the broadest reasonable construction of
the claim phrase is a “rate at which media data elements are transferred to
the server buffer.” Id.
Patent Owner contends that the ’611 patent specification expressly
addresses the “constant fill rate of the server buffer” as it relates to variable-
bit rate (VBR) encoded data, stating that:
In this steady state condition, the media data is sent at a rate
that matches the constant fill rate of the server buffer, and is
received at the same rate by the user computer if there are no
interruptions in the transmission of media data between the
server and the user's computer (with some variation in the case
of VBR content).
Prelim. Resp. 19–20 (quoting Ex. 1001, 7:65–8:4). Thus, the Patent
Owner argues Petitioner asserts incorrectly that the claim phrase is indefinite
as applied to VBR-encoded data. Prelim. Resp. 19. In addition, Patent
Owner notes that Petitioner’s proposed construction reads the term
“constant” out of the claim phrase. Id. at 20. Thus, Patent Owner submits
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that a proper interpretation is “a data rate corresponding to the constant rate
that frames are represented in the media data in normal playback.” Id.
Based on the present record, we agree with Patent Owner that
Petitioner’s construction reads the term “constant” out of the claim phrase
“constant fill rate of a server buffer” and would allow essentially any rate to
suffice. We also are not persuaded by Patent Owner that the rate of filling a
server buffer must be related to the “rate that frames are represented in the
media data” as Patent Owner’s construction suggests. Accordingly, for
purposes of this Decision, we determine that “constant fill rate of a server
buffer” is “the constant rate at which media data elements are transferred to
the server buffer.”
6. Claims 1, 3–5, 8, 9, 12, and 14–16—“wherein the media data elements
is sent at a rate that matches the constant fill rate of a server buffer and
is received at the same rate by the user computer if there are no
interruptions in the transmission of media data between the server and
the user’s computer”
Patent Owner offers a construction for the term “matches” as used in
the claim phrase “the media data elements is sent at a rate that matches the
constant fill rate of a server buffer” as recited in claims 1, 3–5, 8, 9, 12, and
14–16. Prelim. Resp. 20–21. Petitioner does not offer a construction of this
claim phrase. Based on the ’611 patent specification (Ex. 1001, 7:55–8:4),
Patent Owner contends that “matches the constant fill rate of a server buffer”
means that “at any given time during uninterrupted transmission, the data
rate out of the server matches the data rate into its buffer.” Prelim. Resp. 21.
We are persuaded by Patent Owner’s proposed construction that the
term “matches” applies to the data rates into and out of the buffer. Based on
the record before us, we agree with Patent Owner’s proposed construction.
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B. Chen and Chen FH
Petitioner contends that claims 1–18 are obvious based on Chen and
Chen FH, relying on the declaration of Nathaniel Polish, Ph.D. (Ex. 1003).
Pet. 16–25. Petitioner provides claim charts showing where Chen and Chen
FH allegedly teach or suggest the limitations of the challenged claims.
Pet. 25–57.
1. Chen (Ex. 1004)
Chen describes a system for the “just-in-time” retrieval of multimedia
files over a computer network. Ex. 1004, [54]. Figure 1 of Chen is
reproduced below.
Figure 1 is a schematic illustration showing a client machine 20 receiving
data streamed from a server machine 21 over a network. Data packets are
loaded into a “server control stream buffer” 1 for streaming over a data
channel 6. Streamed packets are accumulated in a “client agent packet
buffer” 30 for playback. Id. at 4:65−5:44.
Chen describes “NORMAL,” “RUSH,” and “PAUSE” transmission
modes for streaming from a server to a user. Id. at 6:1−15. It describes a
“Water Mark” model for buffering streaming content and “draws a parallel
between the client agent buffer and a water bucket with a spout at the bottom
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that brings water to a person.” Id. at 6:16−19. A bucket has high and low
“water marks.” Id.at 16:28. Water exits the bucket through a spout similar
to data exiting a packet buffer as its content is delivered to a user. See id. at
6:16−54. When water in the bucket is at a level between the water marks,
transmission occurs in the normal mode. Id. at 28–32. The normal mode
carries out frame level pacing, i.e., transmission at the playback rate. Id. at
10:3−4. When the amount of data falls below the low mark, the
transmission mode changes to “rush.” Id. at 6:42−47. In the rush mode,
frame level pacing is ignored and data is transmitted as fast as possible. Id.
at claims 18, 29; Fig. 6.
2. Chen FH (Ex. 1005)
Chen FH, from which issued Chen, the patent applicant submitted a
Declaration in accordance with 37 C.F.R. § 1.131 for the purpose of
predating (“swearing behind”) a cited reference. Ex. 1005, 77−79. The
Declaration references a “Quick Video Server” (“QVS Sever”) exhibit
document alleged by Petitioner to describe a commercial embodiment of
Chen. Id. at 77. The Declaration includes a claim chart mapping the
technical documents provided for the QVS server to the then pending
claims. Id. at 112–19. Chen FH describes a protocol used by the QVS
server and is reproduced below. Ex. 1005, 86.
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The QVS Server Protocol describes “pause,” “normal,” and “rush”
transmission modes. Rush mode is described as “transmit data as fast as
possible, subject to the Round-Robin sharing with other active streams.” Id.
For purposes of this decision, we consider Chen FH to be a
publication. In re Wyer, 655 F.2d 221, 226–27 (CCPA 1981) and
Bruckelmyer v. Ground Heaters, Inc., 445 F.3d 1374, 1378–79 (Fed. Cir.
2006) establish that an application underlying a published patent, such as the
Chen FH in the present case, is a printed publication. Contrary to Patent
Owner’s contentions, Bruckelmyer does not require that an issued patent
suggests turning to the underlying application in order to establish the file
history was publicly accessible. Prelim. Resp. 11–12 (citing Bruckelmyer,
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445 F.3d at 1379). Instead, as discussed in In re Wyer, the abstract of the
issued patent is sufficient to indicate the subject matter and substance of the
underlying patent application and establish its public accessibility. 655 F.2d
2 at 227; see also Bruckelmyer, 445 F.3d at 1379 (noting sufficiency of
abstract in In re Wyer). For purposes of this Decision and based on the
present record, we determine that Chen FH is available as prior art against
the challenged claims.
3. Analysis
Petitioner contends that the combination of Chen and Chen FH
discloses the limitation that “the media data elements is sent at a rate that
matches the constant fill rate of a server buffer” as recited in claims 1, 3–5,
8, 9, 12, and 14–16. Pet. 19. Specifically, Petitioner contends that Chen and
Chen FH disclose that because Chen’s server includes a stream buffer that
has only 1–5 frames when the system is in normal mode, the stream buffer is
emptying at about the playback rate and the stream buffer fills at “about” the
playback rate to avoid overflow or underflow conditions. Pet. 19 (citing
Ex. 1003 ¶ 63).
Patent Owner contends that neither Chen nor the Chen FH discloses
that “the media data elements is sent at a rate that matches the constant fill
rate of a server buffer.” Prelim. Resp. 25–27. Specifically, Patent Owner
argues that Petitioner’s reliance on the small number of frames in the server
buffer is not relevant to the server buffer filling and sending limitation. Id.
at 26. Instead, Patent Owner argues that Chen discloses a server buffer but it
does not teach that data flows out of the server at a rate that matches the
constant fill rate of data coming into the buffer. Id. at 27.
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Based on the record before us, Petitioner has failed to show that Chen
and Chen FH teach or suggest that the server buffer in Chen fills at a
constant rate that matches the rate of data coming out of the buffer.
Petitioner’s citations to Chen (Pet. 19 (citing Ex. 1004, 5:17–34) and Pet. 31
(citing Ex. 1004, 9:21–30, claim 42)) and the Polish Declaration (Ex. 1003
¶ 63) do not demonstrate that the data rate out of the server matches the data
rate into its buffer and is “constant.” Indeed, Petitioner’s argument and
evidence fails to address whether the rate is constant. In addition, we do not
find the argument’s reliance on the small number of frames establishes that
the rate of filling the server buffer is about at about playback rate. In sum,
Petitioner has not provided persuasive evidence that Chen and Chen FH
teach that “the media data elements is sent at a rate that matches the constant
fill rate of a server buffer,” which appears in every challenged claims of the
’611 patent.
Based on the foregoing, we find Petitioner has not demonstrated that
there is a reasonable likelihood that it would prevail in showing that claims
1–18 are obvious in view of Chen and Chen FH.
C. Chen, Chen FH, and Carmel
Petitioner asserts that if a different construction of “constant fill rate”
is adopted by the Board, Carmel discloses the claim limitations that recite
this claim phrase. Pet. 57–58.
Carmel discloses Network Media Streaming via real-time
broadcasting from a transmitting computer to client computers over a
network, including providing at the transmitting computer a data stream
having a given data rate, and dividing the stream into a sequence of slices,
each slice having a predetermined data size associated therewith. Ex. 1009,
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[54], [57]. Carmel discloses that the slices are encoded in a corresponding
sequence of files, each file having a respective index, and the sequence is
uploaded to a server at an upload rate generally equal to the data rate of the
stream, such that the one or more client computers can download the
sequence over the network from the server at a download rate generally
equal to the data rate. Id. at [57].
We are not persuaded by Petitioner’s argument that the disclosure in
Carmel related to uploading media data elements to the server teaches or
suggests that “the media data elements is sent at a rate that matches the
constant fill rate of a server buffer” as recited in the challenged claims.
Petitioner has not adequately shown that Carmel, which does not discuss the
fill rate of server buffers, discloses that the rate of data flowing into the
server buffer matches the rate of data flowing out of the server buffer.
Petitioner has not provided persuasive evidence or arguments that Carmel in
combination with Chen and Chen FH discloses the matching constant fill
rate limitation.
Accordingly, we find that Petitioner has failed to show that Chen,
Chen FH and Carmel render claims 1–18 obvious.
D. Chen, Chen FH, Carmel, and ISO-11172
Petitioner asserts that if a different construction of “constant fill rate”
is adopted by the Board, Chen, Chen FH, Carmel, and ISO-11172 disclose
the claim limitations that recite this claim phrase. Pet. 58–59. Petitioner’s
arguments suffer from the same deficiency identified above for the ground
based on Chen and Chen FH and the ground based on Chen, Chen FH, and
Carmel. Petitioner’s alternative argument is based on the ISO-11172
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disclosures of constant bit-rate (CBR) encoding of multimedia. Pet. 59
(citing Ex. 1007, 22; Ex. 1008, 27; Ex. 1003 ¶ 77).
We find that Petitioner’s argument that “[b]y using a constant bit rate,
the server will have a constant fill rate when the server buffer is filled at the
playback rate as taught by Carmel” (Pet. 59 (citing Ex. 1003 ¶ 79)), is
conclusory and not persuasive. Petitioner has not shown how the encoding
of multimedia, as disclosed in the MPETG-1 standard of ISO-11172,
discloses “the media data elements is sent at a rate that matches the constant
fill rate of a server buffer” as recited in the challenged claims, such that the
rate of data flowing into the server buffer matches the rate of data flowing
out of the server buffer. We do not find convincing Petitioner’s argument or
evidence that CBR encoding as applied to Chen teaches that the server
buffer fill and outflow rates match. Pet. 58–59.
Based on the record before us, we determine that Petitioner has not
demonstrated that there is a reasonable likelihood that it would prevail in
showing that Chen, Chen FH, Carmel, and ISO-11172 render claims 1–18
obvious.
III. CONCLUSION
For the foregoing reasons, we determine that the information
presented in the Petition does not establish a reasonable likelihood that
Petitioner would prevail in establishing that claims 1–18 are unpatentable
under 35 U.S.C. § 103 as obvious in view of: (1) Chen and Chen FH; (2)
Chen, Chen FH, and Carmel; and (3) Chen, Chen FH, Carmel, and ISO-
11172.
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IV. ORDER
Accordingly, it is
ORDERED that pursuant to 35 U.S.C. § 314, an inter partes review is
hereby denied as to all grounds raised in the Petition for the reasons stated
above and no trial is instituted.

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PETITIONER:
Kevin M. O’Brien
Richard V. Wells
Matthew S. Dushek
BAKER & MCKENZIE LLP
Duodecad_WAG@bakermckenzie.com
richard.wells@bakermckenzie.com
matt.dushek@bakermckenzie.com

Frank M. Gasparo
Jeffri A. Kaminski
VENABLE LLP
FMGasparo@Venable.com
JAKaminski@Venable.com

PATENT OWNER:
Ronald Abramson
Ernest D. Buff
ronald.abramson@lewisbaach.com
ebuff@edbuff.com

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