Obviousness

tool_code
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The user is asking for an obviousness analysis of US patent 8230101 under 35 U.S.C. § 103, based on the provided prior art. I need to identify combinations of these references that would make the claims obvious and explain the motivation to combine them.

I will focus on the independent claims (1, 6, 7, 12) and examine the listed prior art documents to see how their elements could be combined to meet the limitations of these claims.

The core innovative aspects of US8230101 are:

1. A server device (media player) with internal storage.
2. Transferring part of digital content to a network storage device.
3. A unified list presented to a network player, showing both internal and network-stored content as if all were local, maintaining the original tree structure.
4. Searching for content location.
5. Stream-delivery from the network storage device to the network player (potentially directly) if content is on the network.
6. Specific handling of unrecoverable content during transfer (Claim 1: not transferred; Claim 6: transferred with user permission).

Let's look at the prior art provided in the patent itself to see if any references individually or in combination disclose these features. The "Cited By" and "Citations" sections on Google Patents are usually good starting points for prior art for obviousness analysis.

The patent itself lists several "Prior art keywords" and "Prior art date" and then a "Patent Document" which is JPH2004-208204A. This document is also listed under "Family Cites Families". I should prioritize references directly cited within the patent's "BACKGROUND ART" or "Citations" section.

I will go through each independent claim and try to find combinations of prior art that address each element.

Prior Art References provided in the patent:

• JPH1021174A: Data transfer system
• JP2000163224A: Media controller system
• JP2001092749A: System for distributing data
• US20020116082A1: Method and system for remote access of personal music
• US20030079016A1: Using NAS appliance to build a non-conventional distributed video server
• US20030225568A1: Emulator-enabled network connectivity to a device
• JP2005167768A: Broadcast program recording method and broadcast receiving apparatus
• EP1596559A2: Method for sharing audio/video content over network, and structures of sink device, source device and message
• JP2005328443A: Home server, home server system and client terminal
• US20060020589A1: System and method for searching for content stored by one or more media servers
• JP2006185473A: Digital content recording / reproducing apparatus and method thereof
• US20060161635A1: Methods and system for use in network management of content
• US20060184972A1: Method and apparatus for content selection in a home media environment
• JP2006304093A: Television broadcast receiving apparatus, television broadcast receiving method, and television system
• JP2006311313A: Broadcast receiving apparatus and broadcast receiving method
• US20060281477A1: Dynamic detection and configuration of networked audio/video components
• US20070002784A1: Systems, methods, and media for notifying users of events on a remote control device
• US7219123B1: Portable browser device with adaptive personalization capability
• US20070238471A1: Method and apparatus for storing data using DLNA network
• US20070288966A1: Method and system for personalized media players
• US20080104219A1: Content Sharing System, Content Management Server, Client Station, Method for Managing Content, Method for Acquiring Content, and Program
• US20090157892A1: Media server device, media server control method, and program
• US20090252176A1: Gateway Device
• US20100198915A1: Content reproducing apparatus
• JP2004208204A: Hard disk recorder (mentioned as "Patent Document" in background)
• UPnP AV Architecture:1, Ritchie, J. et al. (Non-patent citation)

Let's analyze the patent's own description of the background art:

• "Japanese Patent Application Laid-Open No. 2004-208204 (Patent Document) discloses a hard disk recorder for recording television programs that automatically deletes contents corresponding to a predetermined condition from contents stored therein when the hard disk, although with a large capacity, has stored many amounts of contents data so that an insufficient capacity is left for storing a new television program." This reference deletes content, it doesn't transfer it to a network storage for continued access.
• The patent notes that "Even if the hard disk recorder is adapted to transfer a part of the stored contents data to a storage medium such as a DVD-R or the like instead of deleting them, the hard disk recorder is difficult to play the transferred contents as required." This highlights a perceived gap that the invention aims to fill: enabling playback of transferred content as required (i.e., maintaining the illusion of local storage).

The patent also explicitly mentions DLNA and UPnP AV Protocol for metadata and content directory services, which implies that a POSITA would be familiar with these technologies. The "UPnP AV Architecture:1" non-patent citation is very relevant.

Let's break down the claims and identify elements:

Claim 1 (Server device for media):

• Server device for media (media player) with internal storage: This is broadly known. HDD portable players (like the one in the patent, FIG. 1) are a common example.
• Responds to data transmission request from network player by stream-delivering from internal storage: Standard functionality for a media server (DMS in DLNA context).
• Transfer control unit transfers part of held digital contents in internal storage to a network storage device (connected to network, capable of storing data): This is a key element. Transferring to a network storage is known, e.g., NAS. "Part of held digital contents" implies selection, which is plausible.
  • Constraint 1 (Claim 1 only): "wherein said transfer control unit does not transfer... digital contents that cannot be recovered if a network failure occurs during the transferring". This is a specific safety mechanism.
• List information transmission unit transmits list information to network player: Standard for a media server.
  • Constraint 2: "wherein the list information lists the digital contents left in the internal storage device and the digital contents transferred from the internal storage device to the network storage device and stored in the network storage device, and wherein the list information maintains a tree structure of the digital contents in the internal storage device before transferring the digital contents to the network storage device". This is a significant aspect: presenting a unified list that includes virtually stored content, maintaining the original structure.
• Search unit searches for location where held digital contents are currently stored (internal or network): Necessary if content can be in multiple locations.
• Digital contents data transmission processing unit allows stream-delivery from network storage device to network player if search shows network storage device: This is also a key feature, enabling transparent access to remote content.

Claim 6 (Server device for media):

• Identical to Claim 1, except for Constraint 1: "wherein the digital contents that cannot be recovered if a network failure occurs during the transferring of the digital contents from the internal storage device to the network storage device is transferred after obtaining permission from a user".

Claim 7 (Method):

• Corresponds to Claim 1, but as a method.
  • Constraint 1 (Claim 7 only): "wherein the digital contents that cannot be recovered if a network failure occurs during the transferring of the digital contents are not transferred from the internal storage device to the network storage device".

Claim 12 (Method):

• Corresponds to Claim 6, but as a method.
  • Constraint 1 (Claim 12 only): "wherein the digital contents that cannot be recovered if a network failure occurs during the transferring of the digital contents from the internal storage device to the network storage device is transferred after obtaining permission from a user".

Let's search for how prior art addresses these points.

General knowledge in the art (DLNA/UPnP context):

• Media servers (DMS) provide lists of content.
• Media players (DMP) request content from DMS.
• Content can be stored on various devices on a network (NAS, PCs).
• Streaming content over a network is common.
• Managing storage capacity by moving/deleting content is a known problem (as noted by JP2004208204A).

Specific Prior Art Review for Obviousness:

1. JP2004208204A (Patent Document mentioned in Background Art):

• Discloses a hard disk recorder that deletes content to free up space. It explicitly states "it can do nothing but delete a part of the stored contents data in order to store further new contents." It mentions transferring to "a storage medium such as a DVD-R or the like" but notes it's "difficult to play the transferred contents as required." This reference identifies the problem of limited storage and the need to manage it, but does not provide the solution of maintaining seamless playback of transferred content from a network storage.

2. UPnP AV Architecture:1 (Non-patent citation):

• This is fundamental to DLNA. It defines DMS (Digital Media Server) and DMP (Digital Media Player) roles, content directories, metadata, and how DMPs discover and access content from DMS. It would certainly describe mechanisms for listing content, searching, and stream delivery. However, it likely doesn't inherently describe a DMS that virtually manages content distributed across multiple physical devices (internal + network storage) as a single, unified collection from the perspective of the DMP, while maintaining the original tree structure. It focuses on a single DMS presenting its own content.

3. US20030079016A1 (Using NAS appliance to build a non-conventional distributed video server):

• This patent discusses using a Network Attached Storage (NAS) appliance as part of a distributed video server. This is highly relevant to the concept of using a "network storage device" to store media. It implies that a server can distribute its content across different storage components, including network-attached ones.
• Abstract: "A network attached storage appliance is configured as a video server. The NAS appliance has a directory and storage structure where video content is stored. A content delivery system routes video content from the NAS appliance to a plurality of client devices. This provides for a video server that can be expanded in capacity by adding additional NAS appliances."
• This teaches a server using NAS for storage and clients accessing content through the server. This would cover a server device with an internal storage potentially delegating storage to a network storage.

4. US20060020589A1 (System and method for searching for content stored by one or more media servers):

• "A system and method for providing content to a client device from a media server, where the media server and content are registered with a registry service, by initiating a search for desired content at the registry service by the client device." This teaches searching for content across multiple servers (or content sources). While it focuses on a registry, it suggests the concept of a client searching for content which might be held on various networked resources.

5. US20060184972A1 (Method and apparatus for content selection in a home media environment):

• "A client device in a home media environment selects content from one or more content sources." This reinforces the idea of clients accessing content from various sources.

6. US20070238471A1 (Method and apparatus for storing data using DLNA network):

• "A method for storing data using a DLNA network. A storage apparatus stores data to a client apparatus connected to the DLNA network. A client apparatus connected to a DLNA network includes a storage unit that stores data transmitted from a storage apparatus connected to the DLNA network." This explicitly teaches storing data to a client apparatus on a DLNA network. This means a server device could transfer data to another networked device (client or storage).

Combining Prior Art for Obviousness:

Let's consider a combination of a DLNA-compliant media server (DMS) (e.g., as understood from UPnP AV Architecture:1) with a hard disk recorder that manages storage space (JP2004208204A), and the concept of network-attached storage (US20030079016A1, US20070238471A1).

A Person of Ordinary Skill in the Art (POSITA) would be a software engineer or architect familiar with networked media systems, DLNA/UPnP, and data storage management.

Motivation to combine:
The motivation for combining these elements would be to address the known problem of limited storage on portable media players, as explicitly stated in the background of US8230101 and highlighted by JP2004208204A. Instead of deleting content (as in JP2004208204A) or manually transferring to an offline medium like DVD-R (and losing easy playback), a POSITA would be motivated to leverage existing network storage solutions (like NAS, as taught by US20030079016A1 or general network storage as in US20070238471A1) to offload less frequently accessed media. The challenge then becomes how to maintain the "convenience of playback" and a "seamless user experience" for the network player.

Obviousness Argument for Claims 1 and 7 (Server device/Method with non-transfer of unrecoverable content):

1. Server device for media (media player) with internal storage that stream-delivers to a network player: This is explicitly described in the background of US8230101 as a common use case for HDD portable players acting as DMS in a DLNA network (e.g., with reference to FIG. 3 and the explanation of DMS/DMP and network-playback). UPnP AV Architecture:1 also clearly teaches the functionality of a DMS.

2. Transfer control unit transfers part of held digital contents in internal storage to a network storage device:

   • JP2004208204A teaches managing limited internal storage by moving content (though it defaults to deletion, it mentions transferring to other media).
   • US20030079016A1 teaches using a NAS appliance as part of a video server's storage.
   • US20070238471A1 teaches a storage apparatus storing data to a client apparatus on a DLNA network.
   • A POSITA, motivated by the problem of limited internal storage and the desire to retain content without deletion (as hinted at by JP'204 mentioning DVD-R transfer), would find it obvious to transfer "part of held digital contents" from the internal storage to an available "network storage device" (e.g., a NAS) for capacity management. The idea of selecting "part of" the content based on criteria (e.g., least played, as suggested in US8230101's detailed description) would also be a matter of design choice for capacity management.

3. List information transmission unit transmits list information listing both internal and network-stored content, maintaining original tree structure:

   • UPnP AV Architecture:1 (and general DLNA knowledge) describes a DMS providing a content directory.
   • Once content is moved to network storage, the DMS (server device) still needs to present a unified view to the DMP. A POSITA seeking to maintain the "convenience of playback" and avoid confusing the user (as noted in the problem statement of US8230101) would be motivated to integrate the remotely stored content into the existing content directory structure. Maintaining the "tree structure" (e.g., artist/album/track, as in FIG. 4 of US8230101) is a logical and obvious step to ensure consistent user experience, especially given that the DMS already manages this structure for its internal content. The DMS effectively acts as a proxy or aggregator for the content, regardless of its physical location. This is a common pattern in distributed file systems or content management systems.

4. Search unit searches for location where held digital contents are currently stored:

   • This is a necessary consequence of distributing content across internal and network storage. If the DMS presents a unified list, it must know where the actual content resides when a playback request comes in. This is inherent in any system managing distributed resources. US20060020589A1 and US20060184972A1 highlight the concept of searching for content across multiple sources.

5. Digital contents data transmission processing unit allows stream-delivery from network storage device to network player if search shows network storage device:

   • This is crucial for the "convenience of playback." If content is on the network storage, the server device needs to facilitate its delivery. The patent discusses two ways: indirect (server retrieves then re-transmits) and direct (server tells player to get it directly from network storage using URI).
   • Both direct and indirect streaming from a network source (like a NAS or another server) to a client are known techniques in networked media systems (e.g., HTTP streaming).
   • A POSITA would find it obvious to implement either direct or indirect streaming to ensure playback of the remotely located content, consistent with maintaining a seamless user experience. The choice between direct/indirect would be a design choice based on network topology, server load, and capabilities of the network storage device (e.g., if it has an HTTP server, direct is better).

6. Constraint 1 (Claims 1 & 7): Transfer control unit does not transfer digital contents that cannot be recovered if a network failure occurs during the transferring:

   • The problem of data loss during transfer due to network failure is a well-known issue in data management.
   • It is common practice in data transfer protocols (e.g., transactional file transfers, "copy then delete" rather than "move") to ensure data integrity and recoverability. A POSITA would be motivated to implement robust transfer mechanisms to prevent data loss, especially for valuable digital content. Explicitly avoiding transfers of "unrecoverable" content (or implementing "copy and verify before delete" logic) would be an obvious safety measure for any data management system, regardless of whether it's local or networked. The patent itself highlights this problem: "If the transferring operation... is interrupted by a failure... the original digital content cannot be recovered neither in the internal storage device... nor the network storage device..., which causes a great damage to the user." The solution to prevent such damage is an obvious safeguard.

Conclusion for Claims 1 and 7:
The combination of a standard DLNA DMS (UPnP AV Architecture:1) with the problem of limited internal storage (JP2004208204A), solved by offloading to network storage (US20030079016A1, US20070238471A1), and then preserving the user experience by maintaining a unified, structured content list and facilitating transparent playback from the network storage (general knowledge in networked media systems, reinforced by US20060020589A1 on searching across sources), would be obvious to a POSITA. The specific safeguard against unrecoverable transfers is an obvious design choice for data integrity.

Obviousness Argument for Claims 6 and 12 (Server device/Method with user permission for unrecoverable content):

Claims 6 and 12 are largely identical to Claims 1 and 7, respectively, with one key difference in the transfer control unit:

• Constraint (Claims 6 & 12): Digital contents that cannot be recovered if a network failure occurs during the transferring... is transferred after obtaining permission from a user.
  • This is an alternative approach to handling unrecoverable transfers. Instead of strictly prohibiting them, it allows them with a user override. Providing user options for potentially risky operations, especially when the user explicitly desires to proceed despite warnings (e.g., "I understand this might be risky, but I want to move this content anyway"), is a very common and obvious design pattern in software and system interfaces. It allows for flexibility when strict prohibitions might be too restrictive. A POSITA would be motivated to provide such user control, especially if there are legitimate reasons for a user to override safety defaults (e.g., perceived benefits outweigh the risks for certain content, or a belief that the network is stable enough). This is a simple variation on the data integrity safeguard, offering user choice.

Conclusion for Claims 6 and 12:
Given the obviousness of Claims 1 and 7, the addition of a user permission step for potentially unrecoverable transfers (instead of outright prohibition) is merely an obvious implementation choice to enhance user flexibility, common in software design for operations involving potential data risk.

Therefore, Claims 1, 6, 7, and 12 are likely rendered obvious by combinations of the cited prior art and general knowledge in the field.

Let's refine the specific combination and motivation for each element.

Primary References for Obviousness:

• UPnP AV Architecture:1 (Ritchie et al.): Establishes the foundation of a DLNA DMS (server device) providing content lists and streaming to DMPs (network players).
• JP2004208204A (Hard disk recorder): Identifies the problem of limited storage on media devices and the need to manage content (deletion, or difficult transfer to offline media). This provides the explicit motivation to find a better solution for storage management.
• US20030079016A1 (Using NAS appliance to build a non-conventional distributed video server): Teaches using network-attached storage (NAS) as part of a server's content storage. This provides the means for expanding storage beyond the internal device by leveraging a network storage device.
• US20070238471A1 (Method and apparatus for storing data using DLNA network): Reinforces the idea of transferring data to a networked storage device within a DLNA environment.

Secondary/Supporting References for Specific Elements:

• US20060020589A1 (System and method for searching for content stored by one or more media servers): Supports the concept of searching across distributed content locations.
• US20060184972A1 (Method and apparatus for content selection in a home media environment): Reinforces client selection from multiple content sources.

Motivation for combination:
A POSITA, encountering a portable media player with limited internal storage (as a server, e.g., HDD portable player 10 in US8230101), and aware of existing solutions like deleting content (JP'204) or transferring to inconvenient offline media (JP'204), would be motivated to integrate network storage (US'016, US'471) as a means to expand the effective storage capacity while maintaining accessibility. To ensure a seamless user experience, consistent with the convenience of DLNA/UPnP, the POSITA would find it obvious to present a unified content list (building on UPnP AV Architecture) that includes both locally and remotely stored content under the original organizational structure (e.g., tree structure in FIG. 4 of US8230101). Implementing a search function to locate the content and then streaming it from its current location (internal or network storage) would be necessary and obvious steps to enable playback. The data integrity safeguards (Claims 1/7) or user permission for risky transfers (Claims 6/12) are basic principles of sound data management and user interface design.

Let's ensure the language aligns with §103.

The "present invention" states its object is "to provide a server device for media, a method for controlling a server for media, and a program for the same which is capable of maintaining the convenience of playback in a network player, while properly dealing with the large total size of held digital contents." The combination of prior art directly addresses this stated objective.

Final check on the details of Claim 1 and 7: "said transfer control unit does not transfer, from the internal storage device to the network storage device, the digital contents that cannot be recovered if a network failure occurs during the transferring of the digital contents from the internal storage device to the network storage device". This specific safety feature, as mentioned, is an obvious design choice to prevent data loss during network transfers. Transactional models or "copy and verify then delete original" strategies are well-known to a POSITA.

Final check on the details of Claim 6 and 12: "the digital contents that cannot be recovered if a network failure occurs during the transferring of the digital contents from the internal storage device to the network storage device is transferred after obtaining permission from a user". This is an obvious variation, providing a user override for a safety feature.

The key novelty, if any, would be the seamless integration of network storage into the server's presented content directory such that the network player sees it all as coming from the single server, maintaining the original tree structure. However, the concept of a "virtual" directory or aggregated view of distributed storage is also not entirely new in network file systems or content management. For instance, a network share could aggregate multiple physical drives. While not explicitly in DLNA spec, applying general file system aggregation concepts to a DLNA content directory would be an obvious engineering task for a POSITA to achieve the desired seamless user experience once the decision to use network storage for overflow is made.## Obviousness Analysis of US Patent 8230101 under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would render the independent claims of US patent 8230101 obvious to a person having ordinary skill in the art (POSITA) at the time of the invention (priority date: 2007-03-02). A POSITA in this field would be a software engineer or system architect familiar with networked media systems, Digital Living Network Alliance (DLNA)/Universal Plug and Play (UPnP) protocols, and data storage management. The motivation to combine these references stems from the recognized problem of limited internal storage on portable media devices and the desire to manage large amounts of digital content while maintaining a convenient and seamless user experience, as explicitly stated in the background of US8230101.

Primary Prior Art References:

1. UPnP AV Architecture:1 (Ritchie, J. et al.): This non-patent literature is a foundational document for DLNA/UPnP, defining the roles and interactions of Digital Media Servers (DMS) and Digital Media Players (DMP). It teaches the core functionality of a server device (DMS) providing content lists (content directories) and stream-delivering media to network players (DMP) over a network.
2. JP2004208204A (Hard disk recorder): This patent identifies the problem of limited internal storage on media recording devices. It discloses a hard disk recorder that automatically deletes content to free up space when capacity is insufficient. While it mentions transferring content to offline media like DVD-R, it notes the difficulty in playing such transferred content "as required." This reference provides the clear motivation for a POSITA to seek better solutions for managing limited internal storage that preserve content accessibility.
3. US20030079016A1 (Using NAS appliance to build a non-conventional distributed video server): This patent teaches using Network Attached Storage (NAS) appliances as components of a distributed video server. It discloses a system where video content is stored on a NAS, and a content delivery system routes this content to client devices. This reference provides the technical means for a server device to utilize a "network storage device" to expand its content holding capacity.
4. US20070238471A1 (Method and apparatus for storing data using DLNA network): This patent explicitly teaches methods for storing data using a DLNA network, where a storage apparatus can store data to another client apparatus (which could serve as a network storage device) connected to the DLNA network. This further reinforces the concept of transferring and storing media content to a networked storage device within a DLNA environment.

Obviousness Argument for Independent Claims 1 and 7 (Server device/Method with non-transfer of unrecoverable content):

Claims 1 and 7 describe a media player acting as a server device with an internal storage that transfers part of its digital contents to a network storage device. The server provides a unified content list to a network player, searches for content location, and facilitates stream-delivery from wherever the content is stored. A key feature is that the transfer control unit does not transfer content that cannot be recovered in case of a network failure during transfer.

A POSITA would find the following combination obvious:

• Server device for media (media player) with internal storage, stream-delivering to a network player: This core functionality is well-known in the art, especially within the context of DLNA (DMS to DMP communication) as taught by UPnP AV Architecture:1. The patent itself describes an HDD portable player acting as a DMS.
• Transferring part of digital contents from internal storage to a network storage device: Driven by the problem of limited internal storage highlighted by JP2004208204A, a POSITA would be motivated to offload less frequently accessed content. Leveraging existing network storage solutions, such as NAS appliances as described in US20030079016A1, or generally transferring data to networked devices as in US20070238471A1, would be an obvious solution to expand the effective storage. The decision to transfer "part of" the content based on criteria (e.g., usage patterns) would be a design choice for effective capacity management.
• Unified list information transmitted to network player, maintaining original tree structure: To maintain the "convenience of playback" and a seamless user experience, a POSITA would find it obvious to integrate content stored on the network storage device into the existing content directory structure presented by the DMS (as defined by UPnP AV Architecture:1). Maintaining the original hierarchical "tree structure" (e.g., artist/album/track) for consistency is a logical and common approach in content management and distributed file systems, ensuring that the network player perceives all content as originating from the single server device, regardless of its physical storage location.
• Searching for content location and stream-delivery from network storage device to network player: If content is distributed, the server must be able to locate it. This is an inherent and obvious requirement for any system managing distributed resources. Once located, stream-delivery from the network storage device to the network player is a straightforward application of known networking and media streaming technologies (e.g., HTTP streaming). The server device facilitating either indirect (proxying data) or direct (providing URI to network player) delivery would be an obvious engineering choice to ensure playback, building upon the basic streaming capabilities defined in UPnP AV Architecture:1.
• Transfer control unit does not transfer unrecoverable digital contents if network failure occurs: Preventing data loss during network transfers is a fundamental principle of robust data management. A POSITA would be motivated to implement safeguards, such as transactional transfer models or "copy-and-verify-then-delete" strategies, to ensure data integrity. Explicitly avoiding transfers where recovery is not possible in case of network failure is an obvious safety measure to protect valuable digital content, as the patent itself acknowledges the "great damage to the user" from such failures.

Obviousness Argument for Independent Claims 6 and 12 (Server device/Method with user permission for unrecoverable content):

Claims 6 and 12 are substantially similar to Claims 1 and 7, respectively, but with a specific modification to the transfer control unit: digital contents that cannot be recovered if a network failure occurs during transfer are only transferred after obtaining permission from a user.

Given the obviousness of the core system described for Claims 1 and 7, this modification is an obvious design choice for enhancing user flexibility. In software and system design, it is common practice to provide users with options to override default safety measures or proceed with potentially risky operations after acknowledging the associated risks. A POSITA would be motivated to include such a user permission step to allow transfers that might otherwise be prohibited, accommodating scenarios where a user deems the risk acceptable or necessary. This is a simple and well-known pattern for user interface and system control design, and does not impart non-obviousness to the underlying system.