Obviousness

To analyze the obviousness of US patent 9043481 under 35 U.S.C. § 103, we need to consider whether the differences between the claimed invention and the prior art would have been obvious to a person having ordinary skill in the art at the time the invention was made (priority date June 9, 2004). This involves the Graham Inquiries: determining the scope and content of the prior art, identifying the differences between the claimed invention and the prior art, and assessing the level of ordinary skill in the art. We also consider "secondary considerations" if presented, though these primarily relate to nonobviousness.

The patent itself lists several prior art documents under "Citations," which are relevant for this analysis. These include various U.S. patents and non-patent publications. The core of the invention lies in the "account-based" access model, where a voucher leads to the generation of a token, and this token can be used across multiple devices, with a plug-in enforcing terms of service like simultaneous streams or time limits.

A person having ordinary skill in the art in 2004 would likely have a strong understanding of network communication protocols (like HTTP), web technologies (like URLs and cookies), digital rights management (DRM) concepts, streaming media technologies, and server-side programming for content delivery and access control.

Let's examine some combinations of prior art that could render the claims obvious:

Combination 1: US20010045451A1 (Tan) + US6360254B1 (Amazon.Com Holdings, Inc.) + General Knowledge of Media Streaming and Server-Side Logic

• US20010045451A1 (Tan): This patent application, titled "Method and system for token-based authentication," explicitly describes token-based authentication systems. It establishes the concept of a token being generated to grant access after some initial authentication.
• US6360254B1 (Amazon.Com Holdings, Inc.): Titled "System and method for providing secure URL-based access to private resources," this patent teaches the use of secure URLs for controlling access to resources, which is analogous to a publishing point.
• The Obviousness Argument:
  • Scope and Content of Prior Art: Tan teaches token-based authentication, and Amazon.com teaches secure URL-based access to resources. The general knowledge of a skilled artisan in 2004 would include the widespread use of streaming media, the need for access control, and the capabilities of server-side programming to implement business logic.
  • Differences: Claim 1 of US9043481 introduces a "voucher" with a unique ID, generating a "token, separate and distinct from the voucher," and critically, the ability to generate multiple tokens for multiple media players from a single validated voucher. The apparatus claims (5 and 9) parallel this method.
  • Motivation to Combine: A person of ordinary skill, faced with the business problem of allowing users flexible access to purchased media across multiple devices (as articulated in US9043481's background, noting the limitation of "license-based" systems to a single media player), would be motivated to combine the token-based authentication of Tan with the secure URL access of Amazon.com. To achieve the "account-based" access model, it would be an obvious step to allow the initial "voucher" (representing a user's transaction) to be validated once and then used to issue multiple, device-specific "tokens." This is a logical extension of managing access for a single user across their various devices, where the transaction ID from the voucher serves as the central account identifier. The implementation of this logic would naturally reside on a server, akin to the media access controller server 270 described in US9043481.
  • The "separate and distinct" nature of the token from the voucher is inherently present in token-based authentication schemes like Tan's, where a token is issued after an initial authorization.

Combination 2: US20030037070A1 (Firstlook.Com) + US6718328B1 (Akamai Technologies, Inc.) + US20060095779A9 (Bhat) (though this was published after the priority date, it shows the direction of the art) or general knowledge of server-side plugins for content delivery.

• US20030037070A1 (Firstlook.Com): This application, "Streaming media security system," addresses security for streaming media. This reference would inform a skilled artisan about common methods for securing media streams.
• US6718328B1 (Akamai Technologies, Inc.): Titled "System and method for providing controlled and secured access to network resources," Akamai teaches methods for controlling and securing access to network resources, which can be extended to media content. This patent also mentions the use of a time window for access.
• General Knowledge of Server-Side Plugins: In 2004, the use of server-side plugins (like those for web servers or media servers) to extend functionality and implement custom business logic was common practice. For instance, Windows Media Server supported Active Script Event Handler Plug-ins, as noted in US9043481 itself.
• The Obviousness Argument:
  • Scope and Content of Prior Art: Firstlook.com and Akamai teach securing and controlling access to network resources, including streaming media, with Akamai specifically mentioning time-limited access. The general knowledge of a skilled artisan includes using server-side plugins for custom logic.
  • Differences: US9043481 details a "custom plug-in 350" running on a media access manager server 300 to enforce terms of service like maximum simultaneous streams or terminating streams based on an expired voucher end-time (as illustrated in FIG. 4).
  • Motivation to Combine: Given the need to enforce business rules for streaming media, a person of ordinary skill would be motivated to combine the secure streaming techniques of Firstlook.com and Akamai with known server-side plugin architectures. Implementing rules such as a "maximum number of simultaneous streams" or "time window for use" via a plugin would be an obvious application of existing technologies to solve a known problem in media distribution (preventing unauthorized or over-authorized use). The concept of terminating a stream when its authorized time expires is directly addressed by Akamai's time-windowed access and is a straightforward piece of logic for a server-side component.

Combination 3: US20090287837A1 (Felsher) (priority date 2000-07-06) + Any of the above, in combination with general networking and content delivery knowledge.

• US20090287837A1 (Felsher): This patent application (priority 2000-07-06), titled "Information record infrastructure, system and method," discusses managing access to information records based on authorizations, and could be seen to broadly cover aspects of managed access. While not directly teaching media streaming, the underlying principles of authorization and access control for digital information are relevant.
• The Obviousness Argument:
  • Scope and Content of Prior Art: Felsher provides a general framework for authorization and access to digital information. Combined with the more specific media access control references and general knowledge of streaming and web technologies, a broad system for managed media access could be envisioned.
  • Differences: The specific "account-based" model for media, with vouchers, distinct tokens, and multi-device access, plus specific enforcement mechanisms via a plugin.
  • Motivation to Combine: A skilled artisan, seeking to apply Felsher's general information access concepts to the specific domain of network media (as detailed in the other prior art), would be motivated to adapt its principles to an account-based system to allow greater flexibility for users while maintaining publisher control.

Overall Obviousness Conclusion:

A person having ordinary skill in the art in 2004 would have been motivated to combine elements from the cited prior art to arrive at the claimed invention in US9043481. The desire to offer more flexible "account-based" media access (as opposed to device-restricted "license-based" access) was a known business need, driven by the proliferation of personal media players. The individual components of US9043481 – voucher validation, token generation, secure content delivery, and server-side enforcement of terms of service – were each present in various forms in the prior art. The combination of these known elements to create a system that allows a single purchase (voucher) to grant access via multiple, distinct tokens across different devices, with robust server-side control over simultaneous streams and time limits via a plug-in, would likely have been considered an obvious integration and application of existing technologies to meet an identified market demand.