US 8566461

Here's a concise summary of US Patent 8566461:

Title: Managed access to media services

Assignee: Digital River Inc

Inventors: Gyuchang Jun, Kurt Huang, Duane Kuroda

Filing Date: 2005-06-08

Issue Date: 2013-10-22

Abstract: The patent describes methods, apparatuses, and systems for managing account-based access to media services. A media access controller server validates a "voucher" (an authorization for content access) and generates a "token." A separate media access manager server then validates this token to grant access to the content. This manager server can employ a custom plug-in to enforce publisher-defined terms of service, such as limiting the number of simultaneous streams per voucher or enforcing a time window for voucher validity, terminating streams if the voucher's end time has passed.

Plain-Language Overview of Independent Claims:

• Independent Claim 1 (Method Claim): This claim describes a method for controlling access to online media. It involves two main steps:

  1. Validating a token: Before allowing access to network content at a specific "publishing point," a system first validates a "token." This token is distinct from, but created based on, an initial "voucher." The voucher itself has been validated as a legitimate authorization and includes the publisher's rules for how the content can be delivered (terms of service). The token itself contains a unique identifier linked to the original transaction that granted access via the voucher.
  2. Denying access based on terms of service: If the validated token doesn't comply with the publisher's terms of service, access to the content is denied. A key term of service mentioned is a "maximum number of streams" allowed simultaneously on a server for a single transaction (identified by the unique ID). Access is denied if the current number of active streams associated with that unique ID meets or exceeds this maximum.

• Independent Claim 9 (Apparatus Claim): This claim describes a system (apparatus) designed to manage access to network content, comprising:

  1. A token validator: This component is configured to check the validity of each token before granting access to network content. Each token signifies authorization to access content at a publishing point, having been generated from a validated voucher. The voucher includes the publisher's terms of service and a unique transaction ID.
  2. A compliance checker: This component determines if the validated token adheres to the publisher's terms of service linked with the voucher. These terms include a maximum number of concurrent streams allowed per voucher on a server. The checker reports non-compliance if the number of active streams linked to that voucher on the server goes over this maximum, and consequently, the checker denies access to the network content.

Uncertainty Regarding CAFC Dockets:
As of June 10, 2026, searches for US patent 8566461 (or US8566461B1) within the U.S. Court of Appeals for the Federal Circuit (CAFC) dockets for 2026 did not yield any specific cases or related proceedings. Therefore, there is no authoritative information available through the conducted search indicating active litigation or appeal concerning this patent in the CAFC for the current year.

As of April 26, 2026, no specific litigation involving US patent 8566461 was found through the conducted searches of publicly available litigation databases like Unified Patents, PACER, or the U.S. Court of Appeals for the Federal Circuit (CAFC) dockets.

While PACER allows for nationwide searches of federal court cases, it requires a registered account and charges fees for accessing case information and documents. Similarly, CAFC records for cases filed after March 1, 2012, are available through PACER, and older records require specific requests and may incur fees. The search results did not yield any direct listings for litigation related to US patent 8566461.

Proceedings overview

As of June 10, 2026, there are no AIA trial proceedings (Inter Partes Review, Post-Grant Review, or Covered Business Method) on file for US Patent 8566461 according to the USPTO Open Data Portal and conducted web searches. This means the patent's claims have not been challenged or modified through these specific PTAB trial mechanisms. The bottom-line defensive posture for a defendant is that the patent claims remain as granted, and there is no PTAB history of invalidation or affirmance to leverage.

Strategic summary

Currently, all 13 claims of US8566461 remain untested by any AIA trial proceeding. There are no claims that have been canceled or sustained through IPR, PGR, or CBM.

Given the absence of any PTAB proceedings, the estoppel landscape is entirely open. A potential defendant facing assertion of this patent is not barred by § 315(e)(2) from raising any prior art grounds they deem relevant in a new PTAB petition, as no prior challenges exist.

The lack of PTAB activity is a notable signal. Patents that are actively asserted or of significant commercial interest often become targets for IPRs or other AIA trials. The absence of such challenges for US8566461 could suggest that it has not been heavily asserted, or that prior art challenging its claims has not been identified and brought before the PTAB. There are no patterns of repeated petitions by the same entity, aggressive appeals by the patent owner, or involvement of defensive aggregators like Unified Patents, as there are no proceedings at all.

Recommended next steps

Since there is no PTAB activity on US Patent 8566461, the recommended next steps for a defendant facing assertion of this patent would involve:

• Prior Art Search and Analysis: Conduct a thorough prior art search to identify any relevant art that could form the basis for an IPR, PGR, or CBM petition if appropriate.
• Validity Assessment: Perform a detailed validity analysis of all asserted claims against the discovered prior art, evaluating the likelihood of successfully challenging the patent's validity in a PTAB proceeding or district court.
• Monitoring: Continue to monitor PTAB dockets for any newly filed petitions related to US8566461, as the situation could change if a new challenger emerges.

Inventors

• Gyuchang Jun: Employer not explicitly stated but assigned patent rights to Bitpass, Inc. at the time of filing.
• Kurt Huang: Employer not explicitly stated but assigned patent rights to Bitpass, Inc. at the time of filing.
• Duane Kuroda: Employer not explicitly stated but assigned patent rights to Bitpass, Inc. at the time of filing.

The inventors assigned their rights to Bitpass, Inc. on the same day the patent application was filed (2005-06-08 executed, recorded 2005-06-09), suggesting an association with Bitpass, Inc. at that time.

Original assignee

The entity named as the current assignee on the issued patent (US8566461B1) and the assignee at the time of grant was Digital River Inc.. Digital River Inc. is an operating company primarily engaged in providing global e-commerce solutions, including online storefronts, payment processing, and digital marketing services, especially for software and digital product distribution. Digital River Inc. is currently an active, operating company.

Assignment timeline

• 2005-06-08 (executed) / recorded 2005-06-09 — Reel 016679/0419

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: HUANG, KURT, JUN, GYUCHANG, KURODA, DUANE
  • Assignee: BITPASS, INC.
  • Correspondent: BLAKELY, SOKOLOFF, TAYLOR & ZAFMAN LLP, 12400 WILSHIRE BLVD. 7TH FLOOR, LOS ANGELES, CA 90025. This correspondent firm recurs later in the chain.
  • Context: Initial assignment from inventors to a startup company shortly after the priority date.

• 2007-01-22 (executed) / recorded 2007-01-22 — Reel 018788/0031

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: BITPASS, INC.
  • Assignee: DIGITAL RIVER, INC.
  • Correspondent: BLAKELY, SOKOLOFF, TAYLOR & ZAFMAN LLP, 12400 WILSHIRE BLVD. 7TH FLOOR, LOS ANGELES, CA 90025. This correspondent firm also handled the previous assignment.
  • Context: Acquisition or transfer of patent rights from a startup (Bitpass) to a larger e-commerce operating company (Digital River) prior to patent issuance.

• 2015-02-12 (executed) / recorded 2015-02-12 — Reel 034980/0698

  • Conveyance: SECURITY AGREEMENT - PATENT
  • Assignor: DIGITAL RIVER, INC.
  • Assignee: MACQUARIE US TRADING LLC
  • Correspondent: MCDERMOTT WILL & EMERY LLP, 227 WEST MONROE STREET, CHICAGO, IL 60606. This correspondent firm recurs later in the chain.
  • Context: Digital River Inc. granted a security interest in the patent as collateral for financing.

• 2015-02-12 (executed) / recorded 2015-02-12 — Reel 034981/0429

  • Conveyance: SECURITY AGREEMENT - PATENT
  • Assignor: DIGITAL RIVER, INC.
  • Assignee: CORTLAND CAPITAL MARKET SERVICES LLC, AS COLLATERAL AGENT
  • Correspondent: MCDERMOTT WILL & EMERY LLP, 227 WEST MONROE STREET, CHICAGO, IL 60606. This correspondent firm also handled the previous security agreement.
  • Context: Digital River Inc. granted another security interest in the patent as collateral for financing, likely related to the same financial transaction as the previous entry.

• 2021-06-01 (executed) / recorded 2021-06-01 — Reel 056448/0001

  • Conveyance: SECURITY AGREEMENT - PATENT
  • Assignor: DIGITAL RIVER, INC., DR GLOBALTECH, INC., DR MYCOMMERCE, INC., DIGITAL RIVER MARKETING SOLUTIONS, INC., DR APAC, LLC, DANUBE PRIVATE HOLDINGS II, LLC
  • Assignee: CERBERUS BUSINESS FINANCE AGENCY, LLC, AS THE COLLATERAL AGENT
  • Correspondent: PROSKAUER ROSE LLP, 11 ORANGE AVENUE, SUITE 1600, ORLANDO, FL 32801.
  • Context: Digital River Inc. and related entities granted a further security interest in the patent as collateral.

• 2021-06-01 (executed) / recorded 2021-06-02 — Reel 057252/0637

  • Conveyance: TERMINATION AND RELEASE OF SECURITY INTEREST IN PATENT COLLATERAL
  • Assignor: MACQUARIE US TRADING LLC
  • Assignee: DIGITAL RIVER, INC.
  • Correspondent: NORTON ROSE FULBRIGHT US LLP, 2200 ROSS AVENUE SUITE 2400, DALLAS, TX 75201. This correspondent firm recurs later in the chain.
  • Context: Release of a previously granted security interest, returning full control to Digital River Inc.

• 2021-06-01 (executed) / recorded 2021-06-02 — Reel 057252/0663

  • Conveyance: TERMINATION AND RELEASE OF SECURITY INTEREST IN PATENT COLLATERAL
  • Assignor: CORTLAND CAPITAL MARKET SERVICES LLC
  • Assignee: DIGITAL RIVER, INC.
  • Correspondent: NORTON ROSE FULBRIGHT US LLP, 2200 ROSS AVENUE SUITE 2400, DALLAS, TX 75201. This correspondent firm also handled the previous release.
  • Context: Release of a second previously granted security interest, further consolidating full control with Digital River Inc.

Timeline diagram

timeline
    title Ownership of US 8566461
    2005 : Filed; Inventors assigned to Bitpass
    2007 : Bitpass assigned to Digital River
    2013 : Patent issued
    2015 : Digital River granted security interest to Macquarie
         : Digital River granted security interest to Cortland
    2021 : Digital River granted security interest to Cerberus
         : Macquarie released security interest
         : Cortland released security interest

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The transfers involve operating companies (Bitpass, Digital River) and financial institutions for security agreements. There are no indications of shell entities with IP-specific naming conventions or registered-agent addresses.
2. Known asserter in the chain — Not present. Digital River Inc. is an operating company, and Macquarie US Trading LLC, Cortland Capital Market Services LLC, and Cerberus Business Finance Agency, LLC are financial entities primarily involved in lending and security, not listed as known patent asserters.
3. Repeat correspondent across the chain — Not present (as a troll pattern). While certain law firms (BLAKELY, SOKOLOFF, TAYLOR & ZAFMAN LLP; MCDERMOTT WILL & EMERY LLP; NORTON ROSE FULBRIGHT US LLP) appear on multiple related recordings within the chain, these instances correspond to specific phases of the patent's lifecycle (initial assignment/acquisition, securing loans, releasing liens) rather than indicating a single correspondent facilitating a series of transfers to anonymous shell entities typical of NPEs.
4. Cascading transfers — Not present. The multiple entries for 2015 and 2021 are security agreements and their subsequent releases, not consecutive ownership transfers through chained LLCs. The actual ownership transfers are separated by significant time periods.
5. Pre-litigation transfer — Not present. No litigation involving this patent was found in prior analysis.
6. Bankruptcy fire-sale — Not present. Digital River Inc. remains an active operating company.
7. Privateering — Not present. There is no evidence of Digital River Inc. transferring the patent to an NPE to assert on its behalf.
8. Defensive aggregator (anti-NPE) — Not present. The chain does not end with any known defensive aggregators.

Verdict

Insufficient data. While the patent ownership history shows transfers between operating companies (Bitpass to Digital River) and a series of security interests and their releases with financial institutions, there are no strong or weak signals indicating an NPE pattern. The current assignee, Digital River Inc., is an operating company. No litigation has been identified, and no transfers to known shell entities or patent asserters are present in the assignment records.

For verification, see the USPTO Assignment Center search for US8566461: https://assignmentcenter.uspto.gov/patents/8566461/assignments.

Most Relevant Prior Art for US Patent 8566461

To identify the most relevant prior art for US Patent 8566461, we will examine the patents cited by the examiner during the prosecution of US8566461. A definitive 35 U.S.C. § 102 anticipation analysis requires a full review of each cited patent's specification and claims, alongside expert legal interpretation, which is beyond the scope of this AI analysis. The following assessment of "potential anticipation" is based on the titles and available abstracts of the cited patents, identifying high-level areas of overlap with the independent claims of US8566461.

The independent claims of US8566461 generally cover:

• Claim 1 (Method): Validating a token (generated from a validated voucher with publisher's terms of service), denying access to network content if the token doesn't comply with terms, specifically a maximum number of simultaneous streams associated with a unique transaction ID.
• Claim 9 (Apparatus): An apparatus with a token validator and a checker for compliance with publisher's terms of service, including a maximum number of streams associated with a voucher, reporting non-compliance, and denying access.

Below are the patents cited by the examiner, with their details and a high-level assessment of potential anticipation:

Examiner-Cited Patents

1. US6484197B1

• Full Citation: US6484197B1 (International Business Machines Corporation) - Filtering incoming e-mail
• Publication/Filing Date: Publication: 2002-11-19 (Priority: 1998-11-07)
• Brief Description: This patent describes a system for filtering incoming e-mail based on various criteria. While it deals with network communication, its specific focus on e-mail filtering is distinct from managed media access.
• Potential Anticipation (35 U.S.C. § 102): Unlikely to directly anticipate the core elements of US8566461. Its focus on e-mail filtering does not appear to involve token-based access to media services or enforcement of stream limits.

2. US6505300B2

• Full Citation: US6505300B2 (Microsoft Corporation) - Method and system for secure running of untrusted content
• Publication/Filing Date: Publication: 2003-01-07 (Priority: 1998-06-12)
• Brief Description: This patent generally relates to securely running untrusted content by isolating it within a protected environment.
• Potential Anticipation (35 U.S.C. § 102): While dealing with "secure content," the method of "securely running untrusted content" by isolation differs significantly from the token/voucher system and stream-count enforcement of US8566461. It may broadly cover "secure access" but not the specific mechanics.

3. US20030037070A1

• Full Citation: US20030037070A1 (Firstlook.Com.) - Streaming media security system
• Publication/Filing Date: Publication: 2003-02-20 (Priority: 2001-07-31)
• Brief Description: This application describes a streaming media security system.
• Potential Anticipation (35 U.S.C. § 102): The title "Streaming media security system" suggests a high degree of relevance. It potentially anticipates aspects of managing access to network content, especially for streaming media. A detailed review would be needed to determine if it discloses a token/voucher system with terms of service enforcement, particularly regarding simultaneous streams.

4. US6718328B1

• Full Citation: US6718328B1 (Akamai Technologies, Inc.) - System and method for providing controlled and secured access to network resources
• Publication/Filing Date: Publication: 2004-04-06 (Priority: 2000-02-28)
• Brief Description: This patent describes providing controlled and secured access to network resources, which can include content.
• Potential Anticipation (35 U.S.C. § 102): This patent's focus on "controlled and secured access to network resources" is broadly relevant. It could potentially anticipate aspects of token-based authentication for access. Specifics on vouchers, explicit publisher terms of service, and concurrent stream limits would require a detailed comparison to US8566461's claims.

5. US6779115B1

• Full Citation: US6779115B1 (Digital5, Inc.) - Portable device using a smart card to receive and decrypt digital data
• Publication/Filing Date: Publication: 2004-08-17 (Priority: 2000-02-18)
• Brief Description: This patent describes a portable device using a smart card for receiving and decrypting digital data.
• Potential Anticipation (35 U.S.C. § 102): While related to secure digital data, its reliance on a smart card and decryption for a portable device differs from the network-based voucher/token system of US8566461 for managing multiple streams across potentially multiple devices.

6. US6868403B1

• Full Citation: US6868403B1 (Microsoft Corporation) - Secure online music distribution system
• Publication/Filing Date: Publication: 2005-03-15 (Priority: 1998-02-06)
• Brief Description: This patent describes a secure online music distribution system.
• Potential Anticipation (35 U.S.C. § 102): "Secure online music distribution system" is highly relevant, as music is a type of media. This patent could potentially anticipate methods of managing access to media, especially the secure delivery aspect. A detailed analysis would be needed to check for the token/voucher mechanism, enforcement of terms like maximum simultaneous streams, and account-based access.

7. US20050060389A1

• Full Citation: US20050060389A1 (Ludmila Cherkasova) - System and method for evaluating a capacity of a streaming media server for supporting a workload
• Publication/Filing Date: Publication: 2005-03-17 (Priority: 2003-09-12)
• Brief Description: This application describes a system and method for evaluating the capacity of a streaming media server.
• Potential Anticipation (35 U.S.C. § 102): This patent focuses on server capacity evaluation rather than access management based on user authorization and terms of service. It does not appear to anticipate the core claims of US8566461.

8. US6948061B1

• Full Citation: US6948061B1 (Certicom Corp.) - Method and device for performing secure transactions
• Publication/Filing Date: Publication: 2005-09-20 (Priority: 2000-09-20)
• Brief Description: This patent describes methods and devices for performing secure transactions.
• Potential Anticipation (35 U.S.C. § 102): "Secure transactions" are fundamental to the voucher acquisition in US8566461. This patent might broadly anticipate the transaction aspect but likely not the specific downstream token validation and enforcement of media access terms of service.

9. US20060059346A1

• Full Citation: US20060059346A1 (Andrew Sherman) - Authentication with expiring binding digital certificates
• Publication/Filing Date: Publication: 2006-03-16 (Priority: 2004-09-14)
• Brief Description: This application describes authentication using digital certificates that have an expiring binding.
• Potential Anticipation (35 U.S.C. § 102): The concept of "expiring binding digital certificates" is highly relevant to the time-window aspect of vouchers/tokens in US8566461, particularly claims 5 and 10 which relate to voucher end times and stream termination. It potentially anticipates the use of time-limited authorization mechanisms.

10. US20060085862A1

• Full Citation: US20060085862A1 (Daniel Witt) - Method and system for authorizing multimedia multicasting
• Publication/Filing Date: Publication: 2006-04-20 (Priority: 2004-10-05)
• Brief Description: This application describes a method and system for authorizing multimedia multicasting.
• Potential Anticipation (35 U.S.C. § 102): The "authorizing multimedia multicasting" aspect is directly related to providing access to media. This patent could potentially anticipate methods of authorizing access, but it would need to disclose a token/voucher system and terms of service enforcement for simultaneous streams to directly anticipate US8566461's core claims.

11. US20060095779A9

• Full Citation: US20060095779A9 (Shivaram Bhat) - Uniform resource locator access management and control system and method
• Publication/Filing Date: Publication: 2006-05-04 (Priority: 2001-08-06)
• Brief Description: This patent describes a system and method for uniform resource locator (URL) access management and control.
• Potential Anticipation (35 U.S.C. § 102): This title is highly relevant to the general concept of "managed access to media services," particularly controlling access via URLs (publishing points). It potentially anticipates the general mechanism of managing access, and a detailed review would be needed to see if it includes specific features like tokens, vouchers, and stream-count enforcement.

12. US7603469B2

• Full Citation: US7603469B2 (International Business Machines Corporation) - Provisioning aggregated services in a distributed computing environment
• Publication/Filing Date: Publication: 2009-10-13 (Priority: 2002-01-15)
• Brief Description: This patent describes provisioning aggregated services in a distributed computing environment.
• Potential Anticipation (35 U.S.C. § 102): While dealing with "provisioning services" in a distributed environment, the core of US8566461 is about managed access to media based on specific terms. It may broadly relate to service delivery but not specifically the unique token/voucher and stream-limit enforcement.

13. US7962415B2

• Full Citation: US7962415B2 (Amazon Technologies, Inc.) - Performing automatically authorized programmatic transactions
• Publication/Filing Date: Publication: 2011-06-14 (Priority: 2004-07-19)
• Brief Description: This patent describes performing automatically authorized programmatic transactions.
• Potential Anticipation (35 U.S.C. § 102): This patent's focus on "automatically authorized programmatic transactions" could be relevant to the initial transaction and voucher issuance steps of US8566461. However, it is less likely to anticipate the detailed token validation and ongoing enforcement of media streaming terms.

14. US8051491B1

• Full Citation: US8051491B1 (Amazon Technologies, Inc.) - Controlling use of computing-related resources by multiple independent parties
• Publication/Filing Date: Publication: 2011-11-01 (Priority: 2007-12-10)
• Brief Description: This patent describes controlling the use of computing-related resources by multiple independent parties.
• Potential Anticipation (35 U.S.C. § 102): "Controlling use of computing-related resources by multiple independent parties" is broadly relevant to managing access. It could potentially anticipate the idea of regulating access for multiple users/devices, but a specific disclosure of a token/voucher system and enforcing stream limits for media would be required for direct anticipation of US8566461's claims.

15. US8095972B1

• Full Citation: US8095972B1 (Southern Company Services, Inc.) - Secure authentication for web-based applications
• Publication/Filing Date: Publication: 2012-01-10 (Priority: 2008-10-06)
• Brief Description: This patent describes secure authentication for web-based applications.
• Potential Anticipation (35 U.S.C. § 102): "Secure authentication for web-based applications" is relevant to the initial user interaction and voucher submission in US8566461. It likely covers parts of the authentication process but not necessarily the distinct token generation, terms of service enforcement, or concurrent stream management specific to media access.

16. US8281136B2

• Full Citation: US8281136B2 (Novell, Inc.) - Techniques for key distribution for use in encrypted communications
• Publication/Filing Date: Publication: 2012-10-02 (Priority: 2005-10-21)
• Brief Description: This patent describes techniques for key distribution in encrypted communications.
• Potential Anticipation (35 U.S.C. § 102): This patent's focus is on the secure exchange of cryptographic keys, which is a lower-level security mechanism. It is unlikely to anticipate the higher-level application logic of token/voucher validation and terms of service enforcement for media streaming as claimed in US8566461.

17. US8316091B2

• Full Citation: US8316091B2 (At&T Mobility Ii Llc) - Content management for wireless digital media frames
• Publication/Filing Date: Publication: 2012-11-20 (Priority: 2008-12-01)
• Brief Description: This patent describes content management for wireless digital media frames.
• Potential Anticipation (35 U.S.C. § 102): "Content management for wireless digital media" is highly relevant to US8566461's domain. It could potentially anticipate aspects of managing media content delivery. A detailed comparison would be required to see if it includes a token/voucher system, unique transaction IDs, and enforcement of terms like maximum concurrent streams.

18. US8333317B2

• Full Citation: US8333317B2 (Broadcom Corporation) - System and method for authenticating the proximity of a wireless token to a computing device
• Publication/Filing Date: Publication: 2012-12-18 (Priority: 2003-09-30)
• Brief Description: This patent describes a system and method for authenticating the proximity of a wireless token to a computing device.
• Potential Anticipation (35 U.S.C. § 102): While it uses "token" and "authenticating," its focus on "proximity of a wireless token" is a different mechanism from the network-based, non-proximity token system of US8566461. It is unlikely to anticipate the core claims.

19. US8447858B1

• Full Citation: US8447858B1 (Marvell International Ltd.) - System for improving quality of service for wireless LANS
• Publication/Filing Date: Publication: 2013-05-21 (Priority: 2005-11-18)
• Brief Description: This patent describes a system for improving quality of service (QoS) in wireless LANs.
• Potential Anticipation (35 U.S.C. § 102): This patent focuses on network performance (QoS) rather than user authorization and access control based on specific terms of service. It does not appear to anticipate the core claims of US8566461.

20. WO2002005061A2

• Full Citation: WO2002005061A2 (David Paul Felsher) - Information record infrastructure, system and method
• Publication/Filing Date: Publication: 2002-01-17 (Priority: 2000-07-06)
• Brief Description: This international application describes an information record infrastructure, system, and method.
• Potential Anticipation (35 U.S.C. § 102): The broad title "Information record infrastructure" does not immediately suggest direct anticipation of the specific media access management system of US8566461. A deeper review would be needed to find specific overlaps.

21. US8819253B2

• Full Citation: US8819253B2 (Oracle America, Inc.) - Network message generation for automated authentication
• Publication/Filing Date: Publication: 2014-08-26 (Priority: 2001-11-13)
• Brief Description: This patent describes network message generation for automated authentication.
• Potential Anticipation (35 U.S.C. § 102): "Automated authentication" is a component of US8566461's system. This patent could potentially anticipate aspects of how tokens are authenticated or how the process is automated. However, it's unlikely to cover the full scope of voucher validation, publisher terms, and simultaneous stream enforcement.

Disclaimer: Performing a definitive 35 U.S.C. § 102 anticipation analysis requires a full review of the patent specification and claims, and expert legal interpretation, which is beyond the scope of this AI analysis. The assessment above is based on the titles and available abstracts and identifies potential areas of overlap with the independent claims of US8566461.

Obviousness Analysis (35 U.S.C. § 103) for US Patent 8566461

To determine the obviousness of US Patent 8566461 under 35 U.S.C. § 103, we must identify combinations of prior art references that would have rendered the claimed invention obvious to a person having ordinary skill in the art (POSA) at the time of the invention (i.e., before the priority date of June 9, 2004). This analysis will explain the motivation a POSA would have had to combine these references.

The independent claims of US8566461, as outlined in the summary, broadly cover a system and method for managing access to network content using a token derived from a voucher, and enforcing publisher's terms of service, specifically including a maximum number of simultaneous streams.

Key Elements of Independent Claims 1 and 9:

• Validating a token for network content access, where the token is generated from a validated voucher.
• The voucher has associated publisher's terms of service, and the token includes a unique transaction ID.
• Denying access if the token (or associated activity) does not comply with terms of service.
• Specifically, terms of service include a maximum number of simultaneous streams per unique transaction ID/voucher.
• Denial involves checking current streams against this maximum.
• (For dependent claims) Periodically checking and terminating streams based on a voucher's end time, often implemented via a plug-in on a media server.

Valid Prior Art References for Combination (priority date before 2004-06-09):

Based on the priority date of US8566461 (June 9, 2004), the following examiner-cited patents are considered valid prior art:

1. US20030037070A1 (Firstlook.Com.) - "Streaming media security system" (Priority: 2001-07-31)
2. US6718328B1 (Akamai Technologies, Inc.) - "System and method for providing controlled and secured access to network resources" (Priority: 2000-02-28)
3. US6868403B1 (Microsoft Corporation) - "Secure online music distribution system" (Priority: 1998-02-06)
4. US20050060389A1 (Ludmila Cherkasova) - "System and method for evaluating a capacity of a streaming media server for supporting a workload" (Priority: 2003-09-12)
5. US6948061B1 (Certicom Corp.) - "Method and device for performing secure transactions" (Priority: 2000-09-20)
6. US20060095779A9 (Shivaram Bhat) - "Uniform resource locator access management and control system and method" (Priority: 2001-08-06)
7. US8819253B2 (Oracle America, Inc.) - "Network message generation for automated authentication" (Priority: 2001-11-13)

Obviousness Combination for Independent Claims 1 and 9

A person of ordinary skill in the art (POSA) would have been motivated to combine the teachings of US6868403B1 (Secure online music distribution system), US20050060389A1 (System and method for evaluating a capacity of a streaming media server for supporting a workload), and US8819253B2 (Network message generation for automated authentication) to arrive at the inventions claimed in US8566461.

1. Primary Reference: US6868403B1 (Secure online music distribution system)

• Disclosure: This patent describes a system for the secure online distribution of music. Music is a form of "network content" as defined in US8566461. Such a system would inherently involve processes for user authentication, authorization to access content, handling user transactions (e.g., purchases or subscriptions), and delivering media from a server to a user's media player. Crucially, a secure distribution system would establish and enforce "publisher's terms of service" for content access and would deny access if those terms were not met. It would also employ unique identifiers for transactions to track content access.

2. Secondary Reference: US20050060389A1 (System and method for evaluating a capacity of a streaming media server for supporting a workload)

• Disclosure: This patent explicitly deals with streaming media servers and methods for evaluating their capacity to handle workloads. While focused on evaluation, it highlights the inherent understanding within the art that streaming media servers have finite resources and that the number of concurrent streams directly impacts server performance and user experience.

3. Secondary Reference: US8819253B2 (Network message generation for automated authentication)

• Disclosure: This patent describes techniques for "automated authentication" through "network message generation." In the context of secure access, this would encompass mechanisms for users to obtain and use credentials for accessing network resources. The concept of different stages of authorization, such as a primary entitlement (analogous to a "voucher") leading to a specific, perhaps temporary, access credential (analogous to a "token"), is a well-known security practice to provide flexibility and control in access management.

Motivation for Combination and Obviousness:

A POSA in the field of secure online media distribution (such as one working on the system described in US6868403B1) would be motivated to combine the teachings of these references for several reasons:

• Implementing granular access control with vouchers and tokens (US6868403B1 + US8819253B2): In a secure media distribution system like that of US6868403B1, a POSA would seek to enhance control over content access. Automating authentication and credential generation (as taught by US8819253B2) would naturally lead to a system where a user's initial entitlement (a "voucher" from a transaction, possibly detailed in US6948061B1 on secure transactions) is processed to generate a more specific, perhaps time-limited or device-specific, "token" for actual streaming access. This provides a flexible and revocable means of granting access without re-validating the full transaction for every request. The token would logically include a unique ID from the originating transaction for tracking purposes, a concept familiar from US6868403B1's need to track content usage and US6948061B1's secure transactions.

• Enforcing stream limits as a term of service (US6868403B1 + US20050060389A1): Given the understanding from US20050060389A1 that streaming media server capacity is a critical factor for performance and scalability, a POSA working on a secure online music distribution system (US6868403B1) would be motivated to manage server resources efficiently. Limiting the "maximum number of simultaneous streams" that a user (or a specific transaction identified by its unique ID) could access at any one time is an obvious solution to prevent server overload, ensure fair resource allocation, and implement differentiated business models (e.g., premium users get more concurrent streams). Integrating this technical limitation directly into the "publisher's terms of service" is a straightforward business decision to control content usage and monetize access. Once this term is established, the logical step for a POSA is to implement a mechanism to "check a number of current streams" associated with the unique ID and "deny access" if that number exceeds the defined maximum, as part of the overall compliance check already present in secure access systems (US6868403B1).

Obviousness for Dependent Claims (e.g., Time-based Termination, Plug-in Implementation)

• Time-based Termination (Claim 5, 10): A secure media distribution system (US6868403B1) would likely offer time-limited access (e.g., subscriptions, rentals). The concept of expiring credentials is also common in authentication systems (e.g., US8819253B2's automated authentication). A POSA would be motivated to ensure that media access is automatically terminated when the authorized time window (associated with the voucher or token) expires, to prevent unauthorized prolonged usage and enforce business rules. Periodically checking active streams against their expiry times and terminating expired ones is a well-known method in system administration and security to manage dynamic access rights.

• Plug-in Implementation (Claim 6, 7, 8, 12, 13): The use of "plug-ins" or "event handlers" to extend the functionality of server software (such as a media server or Windows Media Server mentioned in the patent) is a pervasive and well-understood software architectural pattern. A POSA designing or modifying a media access manager server would find it obvious to implement custom logic (like enforcing stream limits or checking expiration times) as a plug-in, rather than altering the core server code, for flexibility, modularity, and ease of deployment.

Conclusion:

The combination of US6868403B1, US20050060389A1, and US8819253B2 (along with general knowledge in the art regarding security and software architecture) would render the claims of US8566461 obvious. A POSA, driven by the desire to manage server resources efficiently, enforce flexible business models for media distribution, and implement robust access control, would have been motivated to combine these teachings to create a system that uses a token derived from a voucher, enforces a maximum number of simultaneous streams as a term of service, and automatically denies or terminates access upon non-compliance or expiration.