Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Charter Communications, Inc.
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`Petitioner
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`v.
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`Sprint Communications Company
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`Patent Owner
`
`
`Patent No. 6,757,907
`Case No. IPR2019-1135
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`
`PETITION FOR INTER PARTES REVIEW
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`TABLE OF CONTENTS
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`
`I.
`
`II.
`
`PRELIMINARY STATEMENT ..................................................................... 1
`
`THE ’7907 PATENT ....................................................................................... 2
`
`A. Overview of the ’7907 Patent ................................................................ 2
`
`B.
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`The Challenged Claims ......................................................................... 4
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`III.
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`STATEMENT OF PRECISE RELIEF REQUESTED ................................. 12
`
`IV. LEVEL OF ORDINARY SKILL .................................................................. 12
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`V.
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`CLAIM CONSTRUCTION .......................................................................... 13
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`A.
`
`B.
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`C.
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`“A video-on-demand system” (claim 1) / “operating a video-on-
`demand system” (claims 21 and 41) ................................................... 14
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`“viewer control signal” (claims 1, 21, 41) .......................................... 15
`
`“transfer . . . [first/second] video signals” (claim 1) /
`“transferring [first/second] video signals” (claims 21, 41) ................. 16
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`D. Agreed Constructions in Comcast Claim Construction Order ............ 17
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`VI. CLAIMS 1-53 ARE UNPATENTABLE OVER THE PRIOR ART ........... 17
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`A. Overview of the Prior Art .................................................................... 17
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`B.
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`C.
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`Ground 1: Sampsell and Yosuke Render Obvious Claims 1-53 .......... 20
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`Ground 2: Sampsell and Yosuke and Browne Render Obvious
`Claims 1-53 Under § 103 .................................................................... 55
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`D. Ground 3: Sampsell and Yosuke and Humpleman Render
`Obvious Claims 1-53 ........................................................................... 64
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`VII. MANDATORY NOTICES ........................................................................... 75
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`A.
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`B.
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`C.
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`Real Party-in-Interest .......................................................................... 75
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`Related Matters .................................................................................... 75
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`Lead and Back-Up Counsel, and Service Information ....................... 76
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`VIII. CERTIFICATION UNDER 37 C.F.R. § 42.24(d) ........................................ 77
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`IX. GROUNDS FOR STANDING ...................................................................... 77
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`CONCLUSION .............................................................................................. 77
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`LIST OF EXHIBITS
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`Exhibit Description
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`Ex. 1001 U.S. Patent No. 6,757,907 to Schumacher et al. (“the ’7907 patent”)
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`Ex. 1002 Declaration of Kevin C. Almeroth (“Almeroth”)
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`Ex. 1003 Curriculum Vitae of Kevin C. Almeroth, Ph.D.
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`Ex. 1004 Prosecution History of U.S. Patent No. 6,757,907
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`Ex. 1005 U.S. Patent No. 6,496,122 to Sampsell (“Sampsell”)
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`Ex. 1006 European Patent Application EP 0 872 987 A2 to Yosuke (“Yosuke”)
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`Ex. 1007 WO 92/22983 to Browne et al. (“Browne”)
`Ex. 1008 RESERVED - OMITTED
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`Ex. 1009 U.S. Patent No. 6,182,094 to Humpleman et al. (“Humpleman”)
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`Ex. 1010 Claim Construction Order from Comcast Cable Commc’ns, LLC v.
`Sprint Commc’ns Co., LP, Case No. 2:12-cv-859-JD, Dkt. 162 (Aug.
`15, 2014, E.D. Pa.) (“Comcast Claim Construction Order”)
`
`Ex. 1011 Sprint’s Opening Claim Construction Br. from Comcast Cable
`Commc’ns, LLC v. Sprint Commc’ns Co., LP, Case No. 2:12-cv-859-
`JD, Dkt. 162 (Aug. 15, 2014, E.D. Pa.) (“Sprint Claim Construction
`Br.”)
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`I.
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`PRELIMINARY STATEMENT
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`Petitioner requests IPR and cancellation of claims 1-53 of the ’7907 patent
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`(Ex. 1001).1 These claims are directed to a video-on-demand (“VOD”) system that
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`allows the viewer to use a computer—instead of a set-top box—to remotely control
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`the display of video content. (’7907 patent, 1:24-26.) The ’7907 patent explains
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`that, when it was filed in 2000, VOD systems already allowed a viewer to use a
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`television set-top box to remotely control the display of video content. (’7907
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`patent, 1:23-35.) However, the ’7907 patent emphasized that using a set-top box
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`for remote control was undesirable because it was a “special component” that
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`could not be used for other purposes, such as “offer[ing] a selection of displays and
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`bandwidths.” (’7907 patent, 1:38-43.) The ’7907 patent attempts to overcome this
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`alleged shortcoming by simply replacing the set-top box with a computer that
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`allows the viewer to remotely control video content displayed on the television,
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`using a high bandwidth to transfer the video content, or displayed on the computer
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`itself, using a lower bandwidth to transfer the video content. (’7907 patent, 1:46-
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`55, Abstract.)
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`But the concept of using a computer to replace a set-top box for remotely
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`controlling video content displayed on a television or on the computer itself was
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`1 In a separate, concurrently filed Inter Partes Review Petitions, IPR2019-1137
`and IPR2019-1139, Petitioner request cancellation of the same claims from the
`’7907 patent.
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`well-known before the ’7907 patent. For example, Sampsell discloses a video
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`display system capable of displaying remotely stored video signals on a television
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`or a remote-control display. (Sampsell, Abstract, 2:18-29.) Just like in the ’7907
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`patent, the viewer in Sampsell can use the remote-control display to select the
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`remotely stored video content to view and select the display (either the television
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`or the remote-control display) on which to view the selected video content.
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`(Sampsell, 7:54-8:2.)
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`Beyond Sampsell, the concept of using a computer to remotely control a
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`video system was known as early as 1991 in Browne and continued to be a known
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`concept of controlling a VOD system, as shown in Yosuke and Humpleman, before
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`the invention of the ’7907 patent. Similarly, the concept of varying the bandwidth
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`for transmitting video content depending on the display has also been a known
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`concept for proving user flexibility, as demonstrated in Yosuke. Accordingly, the
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`’7907 patent’s claimed technology was well-known prior to the invention of the
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`’7907 patent, and rendered obvious by the art submitted in this Petition.
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`II. THE ’7907 PATENT
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`A. Overview of the ’7907 Patent
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`The ’7907 patent’s three independent claims (1, 21, and 41) are generally
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`directed to methods and systems for using a computer to remotely control a VOD
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`system, and offering the user the choice of transferring the selected video content
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`to either a television or to the computer itself at different bandwidths. (’7907
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`patent, 6:42-58, 7:58-8:4, 8:62-9:11.) The patent, like the prior art, recognized
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`limitations in using set-top boxes for remotely controlling a VOD system, and
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`attempted to improve VOD systems by replacing the set-top box with a computer.
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`(Id., 1:53-55.)
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`The ’7907 patent claims require interactions between a “first communication
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`system,” which the patent defines as including “optical fiber systems, wire cable
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`systems, and wireless link systems,” and a “second communication system,” which
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`the patent defines as the “Internet,” and “in particular, the World-Wide Web.” (Id.,
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`2:42-46.) The claims require that transferring video signals to the second
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`communication system use less bandwidth than transferring video signals to the
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`first communication system. (Id., 6:43-49.) Each communication system is
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`coupled to its own display, e.g., the first communication system is coupled to a
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`television and the second communications system is coupled to a computer with a
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`browser. (Id., 2:46-48.)
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`The ’7907 patent claims are directed to a method for controlling the two
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`communications systems using two separate communication interfaces. (Id., 3:1-
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`14.) The claimed VOD system transmits a “control screen signal” to the user over
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`a second communications system, the user then transmits a “viewer control signal”
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`to the VOD system over a communication interface that is coupled to a particular
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`communications system, and in response, the VOD system transmits “video
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`signals” over the user’s selected first or second communications system, where
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`transmitting the video signals to the second communications system uses less
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`bandwidth than transmitting video signals to the first communications system.
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`(Id., 2:29-3:14.)
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`As shown below, Figure 1 of the ’7907 patent demonstrates the interaction
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`between the various claimed systems, interfaces, and displays, and Figure 6 depicts
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`a preferred embodiment of the claimed invention.
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`
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`B.
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`The Challenged Claims
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`This petition challenges claims 1-53 of the ’7907 patent, of which claims 1,
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`21, and 41 are independent. For ease of reference, the Challenged Claims are
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`reproduced below:
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`Claim 1
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`No.
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`Claim Limitation
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`1
`Preamble
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`A video-on demand system comprising:
`
`1[A]
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`1[B]
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`1[C]
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`a first communication interface configured to transfer first video
`signals to a first communication system using a first bandwidth;
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`a second communication interface configured to transfer a control
`screen signal and second video signals to a second communication
`system using a second bandwidth that is less than the first bandwidth;
`and
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`a processing system configured to transfer the control screen signal to
`the second communication interface, receive a viewer control signal
`from the second communication interface, and transfer the first video
`signals to the first communication interface if the first communication
`system is indicated by the viewer control signal or transfer the second
`video signals to the second communication interface if the second
`communication system is indicated by the viewer control signal.
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`Claim 2
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`The video-on-demand system of claim 1 wherein the control screen includes video
`display menu.
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`Claim 3
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`The video-on-demand system of claim 2 wherein second communications interface
`is configured to receive a video display menu selection signal from the second
`communications system, and the processing system is configured to process the
`video display menu selection signal to responsively select the first communications
`interface or the second communications interface to transfer the video signals.
`
`The video-on-demand system of claim 3 wherein the video display menu selection
`signal includes a selection of displays to display the video signals.
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`Claim 4
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` The video-on-demand system of claim 3 wherein the video display menu selection
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`Claim 5
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`signal includes a selection of bandwidths to transfer the video signals.
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`Claim 6
`
`The video-on-demand system of claim 1 wherein the control screen includes a
`video content menu.
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`Claim 7
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`The video-on-demand system of claim 6 wherein the video content menu includes
`a video preview selection.
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`Claim 8
`
`The video-on-demand system of claim 7 wherein second communications interface
`is configured to receive a video preview selection signal from the second
`communications system, and the processing system is configured to process the
`video preview selection signal to responsively transfer a selected video preview as
`the video signals.
`
`The video-on-demand system of claim 8 wherein the control screen includes a
`viewer that is configured to display the selected video previews.
`
`Claim 9
`
`Claim 10
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`The video-on-demand system of claim 6 wherein second communications interface
`is configured to receive a video content menu selection signal from the second
`communications system, and the processing system is configured to process the
`video content menu selection signal to responsively transfer selected video content
`as the video signals.
`
`The video-on-demand system of claim 10 wherein the control screen includes a
`viewer configured to display the selected video content.
`
`Claim 11
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`Claim 12
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`The video-on-demand system of claim 1 wherein the control screen includes a
`video display control menu comprising play, pause, rewind, fast forward, and stop.
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`The video-on-demand system of claim 12 wherein second communications
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`Claim 13
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`interface is configured to receive a video display control menu selection signal
`from the second communications system, and the processing system is configured
`to process the video display control menu selection signal to implement a selected
`video display control.
`
`The video-on-demand system of claim 1 wherein the control screen includes a
`video display control comprising full screen view.
`
`Claim 14
`
`The video-on-demand system of claim 1 wherein the first communication interface
`is configured to interface with optical fiber.
`
`Claim 15
`
`Claim 16
`
`The video-on-demand system of claim 1 wherein the first communication interface
`is configured to interface with wire cable.
`
`Claim 17
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`The video-on-demand system of claim 1 wherein the first communication interface
`is configured to interface with wireless links.
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`Claim 18
`
`The video-on-demand system of claim 1 wherein the second communication
`interface is configured to interface with an internet.
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`The video-on-demand system of claim 1 wherein the second communication
`interface is configured to interface with a world-wide web.
`
`Claim 19
`
`Claim 20
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`The video-on-demand system of claim 19 wherein the control screen comprises a
`web page.
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`Claim 21
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`21
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`Preamble
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`A method of operating a video-on-demand system, the method
`comprising:
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`21[A]
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`21[B]
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`21[C]
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`transferring a control screen signal indicating a control screen to a
`second communication system;
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`receiving a viewer control signal from the second communication
`system; and
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`transferring first video signals to a first communication system using a
`first bandwidth if the first communication system is indicated by the
`viewer control signal or transferring second video signals to the second
`communication system using a second bandwidth if the second
`communication system is indicated by the viewer control signal
`wherein the second bandwidth is less than the first bandwidth.
`
`Claim 22
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`The method of claim 21 wherein the control screen includes a video display menu.
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`Claim 23
`
`The method of claim 22 wherein receiving the viewer control signal comprises
`receiving a video display menu selection signal and transferring the video content
`signals comprises processing the video display menu selection signal to
`responsively select the first communications interface or the second
`communications interface to transfer the video signals.
`
`The method of claim 23 wherein the video display menu selection signal includes a
`selection of displays to display the video signals.
`
`Claim 24
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`Claim 25
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`The method of claim 23 wherein the video display menu selection signal includes a
`selection of bandwidths to transfer the video signals.
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`Claim 26
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`The method of claim 21 wherein the control screen includes a video content menu.
`
`The method of claim 26 wherein the video content menu includes a video preview
`selection.
`
`Claim 27
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`Claim 28
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`U.S. Patent No. 6,757,907
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`The method of claim 27 wherein receiving the viewer control signal comprises
`receiving a video preview selection signal and transferring the video signals
`comprises processing the video preview selection signal to responsively transfer a
`selected video preview as the video signals.
`
`Claim 29
`
`The method of claim 27 wherein receiving the viewer control signal comprises
`receiving a video content selection signal and transferring the video signals
`comprises processing the video content selection signal to responsively transfer
`selected video content as the video signals.
`
`Claim 30
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`The method of claim 21 wherein the control screen includes a video display control
`menu comprising play, pause, rewind, fast forward, and stop.
`
`Claim 31
`
`The method of claim 30 wherein receiving the viewer control signal comprises
`receiving a video display control menu selection signal and transferring the video
`signals comprises processing the video display control menu selection signal to
`responsively implement a selected video display control.
`
`Claim 32
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`The method of claim 21 wherein the control screen includes a video display control
`comprising full screen view.
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`The method of claim 21 wherein transferring the video signals comprises
`interfacing with optical fiber.
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`Claim 33
`
`Claim 34
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`The method of claim 21 wherein transferring the video signals comprises
`interfacing with wire cable.
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`The method of claim 21 wherein transferring the video signals comprises
`interfacing with wireless links.
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`Claim 35
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`Claim 36
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`The method of claim 21 wherein transferring the video signals comprises
`interfacing with an internet.
`
`The method of claim 21 wherein transferring the video signals comprises
`interfacing with a world-wide web.
`
`Claim 37
`
`Claim 38
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`The method of claim 21 wherein transferring the control screen signal comprises
`interfacing with an internet.
`
`Claim 39
`
`The method of claim 21 wherein transferring the control screen signal comprises
`interfacing with a world-wide web.
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`The method of claim 21 wherein the control screen comprises a web page.
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`Claim 40
`
`Claim 41
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`41
`Preamble
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`A product comprising a processor-readable storage medium storing
`processor-executable instructions for performing a method for
`operating a video-on-demand system, the method comprising:
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`41[A]
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`41[B]
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`41[C]
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`transferring a control screen signal indicating a control screen to a
`second communication system;
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`receiving a viewer control signal from the second communication
`system; and
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`transferring first video signals to a first communication system using a
`first bandwidth if the first communication system is indicated by the
`viewer control signal or transferring second video signals to the second
`communication system using a second bandwidth if the second
`communication system is indicated by the viewer control signal
`wherein the second bandwidth is less than the first bandwidth.
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`The product of claim 41 wherein the control screen includes a video display menu.
`
`Claim 42
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`Claim 43
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`The product of claim 42 wherein receiving the viewer control signal comprises
`receiving a video display menu selection signal and transferring the video content
`signals comprises processing the video display menu selection signal to
`responsively select the first communications interface or the second
`communications interface to transfer the video signals.
`
`The product of claim 43 wherein the video display menu selection signal includes a
`selection of displays to display the video signals.
`
`Claim 44
`
`Claim 45
`
`The product of claim 43 wherein the video display menu selection signal includes a
`selection of bandwidths to transfer the video signals.
`
`Claim 46
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`The product of claim 41 wherein the control screen includes a video content menu.
`
`Claim 47
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`The product of claim 46 wherein the video content menu includes a video preview
`selection.
`
`Claim 48
`
`The product of claim 47 wherein receiving the viewer control signal comprises
`receiving a video preview selection signal and transferring the video signals
`comprises processing the video preview selection signal to responsively transfer a
`selected video preview as the video signals.
`
`Claim 49
`
`The product of claim 47 wherein receiving the viewer control signal comprises
`receiving a video content selection signal and transferring the video signals
`comprises processing the video content selection signal to responsively transfer
`selected video content as the video signals.
`
`The product of claim 41 wherein the control screen includes a video display control
`menu comprising play, pause, rewind, fast forward, and stop.
`
`Claim 50
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`Claim 51
`
`The product of claim 50 wherein receiving the viewer control signal comprises
`receiving a video display control menu selection signal and transferring the video
`signals comprises processing the video display control menu selection signal to
`responsively implement a selected video display control.
`
`Claim 52
`
`The product of claim 41 wherein the control screen includes a video display control
`comprising full screen view.
`
`Claim 53
`
`The product of claim 41 wherein the control screen comprises a web page.
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`
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`III. STATEMENT OF PRECISE RELIEF REQUESTED
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`Claims 1-53 of the ’7907 patent are unpatentable and should be canceled in
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`view of the following grounds:
`
`#
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`1
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`2
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`3
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`Ground for Challenge
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`Claims 1-53 are obvious over Sampsell (U.S. Patent No.
`6,496,122, filed June 26, 1998 and issued on December 17, 2002)
`and Yosuke (European Patent Application EP 0 872 987 A2, filed
`March 31, 1998 and published on October 21, 1998)
`
`Claims 1-53 are obvious over Sampsell, Yosuke, and Browne (WO
`92/22983, June 9, 1992 and published December 23, 1992)
`
`Claims 1-53 are obvious over Sampsell, Yosuke, and Humpleman
`(U.S. Patent No. 6,182,094, filed June 24, 1998 and issued on
`January 30, 2001)
`
`
`IV. LEVEL OF ORDINARY SKILL
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`A person of ordinary skill in the art (“POSITA”) regarding the ’7907 patent
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`would have held a bachelor’s degree in electrical engineering, computer science, or
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`a related field with at least five years of experience or research in interactive
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`systems applicable to digital television, including VOD for cable and Internet
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`delivery. (Almeroth, ¶¶44-46.)
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`V. CLAIM CONSTRUCTION
`
`Sprint asserted the ’7907 patent in another district court litigation against
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`different parties. Comcast Cable Commc’ns, LLC v. Sprint Commc’ns Co., LP,
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`Case No. 2:12-cv-859-JD (E.D. Pa.). The parties in that case proposed
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`constructions and the district court construed various terms in the ’7907 patent.
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`Comcast Cable Commc’ns, LLC v. Sprint Commc’ns Co., LP, Case No. 2:12-cv-
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`859-JD, Dkt. 162 (Aug. 15, 2014, E.D. Pa.) (“Comcast Order”). While the
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`Comcast court disagreed with Sprint’s proposed constructions (Comcast Order at
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`28-38), the Board need not resolve those disputes here because the claims read on
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`the prior art under either Sprint’s proposed construction or the Comcast court’s
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`construction.2
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`2 Sprint asserted claims 21, 23, and 36 of the ’7907 patent against Comcast in
`Comcast v. Sprint. Accordingly, the Comcast court only construed terms
`contained in those claims. However, the Comcast court’s constructions for those
`terms apply equally to the same or similar terms found in the remaining claims in
`the patent, as like terms should be construed consistently across all claims in a
`patent. See Omega Engineering, Inc, v. Raytek Corp., 334 F.3d 1314, 1334 (Fed.
`Cir. 2003).
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`A.
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`“A video-on-demand system” (claim 1) / “operating a video-on-
`demand system” (claims 21 and 41)
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`Sprint’s proposed construction and the Comcast court’s construction for
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`these terms are set forth below. (Comcast Order at 28-33.)
`
`Sprint
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`Comcast Claim Construction Order
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`Plain and ordinary meaning, or
`
`Should the Court deem a construction of
`the ordinary meaning necessary:
`operating a system that provides video-
`on-demand
`
`operating a video-on-demand system
`without the use of a set-top box for
`remote control of the video-on-demand
`system
`
`
`For the reasons discussed in Section VI, the prior art renders the challenged
`
`claims invalid under both the Comcast court’s construction and Sprint’s proposed
`
`construction in the prior case. However, Petitioner notes that the Comcast court’s
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`construction, which Petitioner supports, is confirmed by the ’7907 patent. The
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`difference between these two constructions is whether the claimed methods for
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`operating a VOD system must exclude the use of a set-top box for remote control
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`of the VOD system. The Comcast court correctly found that the ’7907 patent
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`disclaims the use of a set-top box for remote control by disparaging the prior art’s
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`reliance on set-top boxes and by not including a set-top box in any one of the
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`patent’s embodiments. (Comcast Order at 28-32; see also ’7907 patent, 1:36-55.)
`
`The difference between these constructions, however, does not impact the outcome
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`of this proceeding, because the prior art, to the extent a set-top box is disclosed,
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`does not use a set-top box for remote control of the VOD system.
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`B.
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`“viewer control signal” (claims 1, 21, 41)
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`Sprint’s proposed construction and the Comcast court’s construction for this
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`term are set forth below. (Comcast Order at 34-35.)
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`Sprint
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`Comcast Claim Construction Order
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`Plain and ordinary meaning, or
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`Should the Court deem a construction of
`the ordinary meaning necessary: a
`signal reflecting viewer control
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`a viewer control signal generated and
`processed without the involvement of a
`set-top box for remote control of the
`video-on-demand system.
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`Petitioner notes that the Comcast court’s construction, which Petitioner
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`supports, is confirmed by the ’7907 patent. The difference between these
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`constructions is related to the dispute presented with the prior term—whether a
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`viewer control signal can be generated without the use of a set-top box for remote
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`control of the VOD system. For the same reasons set forth above, the Comcast
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`court held that disclaimer also applies to this term.3 (Comcast Order at 34-35.)
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`3 The Comcast court found that “[t]he specification does not disparage the use of
`a set-top box for other purposes, such as for decod[ing a video signal] and
`present[ing] it to a television” (Comcast Order at 35), and thus the Comcast Order
`permits the use of a set-top box for purposes other than for remote control.
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`C.
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`“transfer . . . [first/second] video signals” (claim 1) / “transferring
`[first/second] video signals” (claims 21, 41)
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`Sprint’s proposed construction and the Comcast court’s construction for
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`these terms are set forth below. (Comcast Order at 36-38.)
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`Sprint
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`Comcast Claim Construction Order
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`Plain and ordinary meaning, or
`
`Should the Court deem a construction of
`the ordinary meaning necessary:
`sending [first/second] video signals
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`in response to the viewer control signal,
`transferring [first/second] video signals
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`For the reasons discussed in Section VI, the prior art renders the challenged
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`claims invalid under both the Comcast court’s construction and Sprint’s proposed
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`construction in the prior case. Petitioner notes that the Comcast court’s
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`construction, which Petitioner supports, is confirmed by the ’7907 patent. As the
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`Comcast court noted, there is no disagreement in the construction about what it
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`means to transfer a video signal; rather, the constructions differ on the issue of
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`whether the video signal must be sent in response to a viewer control signal.
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`(Comcast Order at 37.) The Comcast court correctly found that as described in the
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`’7907 specification, the video signals are transferred in response to the viewer
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`control signal received from the computer, and therefore construed this term as
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`such. (Comcast Order at 36-37; ’7907 patent, Abstract, 2:61-3:14 , 4:5-7.)
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`D. Agreed Constructions in Comcast Claim Construction Order
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`The parties in Comcast v. Sprint agreed that: (1) “control screen signal”
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`should be construed as “a signal that defines a control screen” and (2)
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`“implementing a viewer control selection” should be construed as “in response to
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`the video control signal, implementing a viewer control selection.” (Comcast
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`Order at 42.) For the purposes of this Petition, Petitioner applies these
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`constructions in Section VI.
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`VI. CLAIMS 1-53 ARE UNPATENTABLE OVER THE PRIOR ART
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`A. Overview of the Prior Art
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`1.
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`Sampsell
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`Sampsell teaches an image display system that is capable of displaying user
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`selected video images on two displays. (Sampsell, Abstract.) Sampsell discloses
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`that the first display device can be a screen or display such as a “cathode ray
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`screen, television screens, liquid crystal displays, and computer data displays.”
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`(Sampsell, 5:13-17.) Sampsell discloses that the second display can be a video
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`remote-control that is integrated with a computer monitor, such as a WEB-TV
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`device. (Sampsell, Abstract, 13:12-16.) The disclosed image display system
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`allows a user to use the video remote-control to direct the system to transmit
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`selected image signals to display on the first display, e.g., television display, and/or
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`the second display, e.g., video remote-control’s computer monitor. (Sampsell,
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`2:18-30.)
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`U.S. Patent No. 6,757,907
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`Sampsell explains that using the video remote-control, the user makes menu
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`selections to select the image signals to view and display on which to view the
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`selected image signals. (Sampsell, 6:53-7:18, 7:54-60.) In response to user inputs,
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`the video remote control produces a control signal and transmits this control signal
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`to an image processor. (Sampsell, 6:53-7:10.) Based on the control signal, the
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`image processor selects the image signals from the image sources and transmits
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`them to the user selected display, e.g., the television or video remote control.
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`(Sampsell, 7:9-18.) Sampsell teaches that “the image sources may be any type of
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`image source capable of outputting image signals. For example, the image sources
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`may be standard television receivers, cable television boxes, digital satellite hook-
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`ups, or data hook-ups as required for a computer or computer television.”
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`(Sampsell, 4:29-34.)
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`2.
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`Yosuke
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`Yosuke teaches a VOD system: “VOD system is a system for providing
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`specific video information and audio information through a plurality of channels
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`on demand of a plurality of clients for providing information.” (Yosuke, 3:20-26.)
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`The VOD system in Yosuke provides video signals to clients in response to a
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`client’s instructions from, for example, a touch panel. (Yosuke, 3:25-28, 6:24-31.)
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`In response to these instructions, video signals are sent from the VOD server to a
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`display. (Yosuke, 3:25-28.)
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`Inter Partes Review No. 2019-1135
`U.S. Patent No. 6,757,907
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`Yosuke discloses displaying video images on a first and/or second display.
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`(Yosuke, Fig. 2, 5:24-6:30.) For example, Yosuke discloses a first video display for
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`“receiving video signals sent from the VOD server for video image display.”
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`(Yosuke, 6:24-31.) Yosuke discloses a second video display (i.e., a touch panel)
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`“for displaying video signals outputted from the client computer and for giving
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`instructions to the client computer.” (Yosuke, 6:24-31.) Yosuke discloses that the
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`transmission line for transmitting video content to the first video display is a higher
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`bandwidth transmission medium than the transmission line for transmitting video
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`content to the second video display. (Yosuke, 12:34-42.)
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`In Figure 7, Yosuke sets forth an embodiment of a control screen that allows