In re WAG Acquisition, LLC
Patent Trial and Appeal Board
Holding
The Federal Circuit affirmed the Board’s finding that Hill anticipated claims 1 and 4. Substantial evidence supported the Board’s findings on the claimed transmission requests, serial-number tracking in the player buffer, and receipt at a rate faster than playback.
Why It Matters
The decision underscores that broad media-buffering claim language can read on aggregate data-transfer functionality in prior art, even where the patent owner urges narrower implementation-specific readings.
Full Summary
Key Points
- The disputed claims covered a media player that requests numbered media data elements, stores them in a buffer, tracks the serial number of the last received and stored element, and receives a predetermined number of elements faster than playback.
- For limitation 1.i.1, substantial evidence supported the Board’s finding that Hill disclosed requests for frames identified by global frame number, including where sources were accessed via a network server or Internet site.
- For limitation 1.g, the court held the Board reasonably found that Hill’s buffer manager maintained the relevant frame-number record needed to determine which frames to request next.
- For dependent claim 4, the court rejected WAG’s narrow reading that each individual data element had to be sent faster than playback; the claim covered an overall receipt rate faster than the playback rate.
- The nonprecedential opinion affirmed the Board’s anticipation ruling in full.
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