US 9451001

Here is a concise summary of US Patent 9451001:

US Patent Number: 9451001
Title: Social networking with video annotation
Current Assignee: ART RESEARCH AND TECHNOLOGY LLC
Inventors: David Hirschfeld, Barry Fernando, Mark C. Phelps
Filing Date: 2014-01-31
Issue Date: 2016-09-20
Abstract: A method and system for annotating Playable Media Files in a social network having a plurality of members, wherein the method includes receiving the Playable Media File from a first member, receiving an annotation from another member, and embedding the annotation in the Playable Media File.

Plain-Language Overview of Independent Claims:

• Independent Claim 1 (Method): This claim describes a method for annotating playable media files in a social network. It involves a member receiving a playable media file, creating an annotation for it, and providing both the annotation and a data profile (which specifies where the annotation should be embedded) to a network server. The network server then embeds the annotation at the specified location. The method also includes steps for determining if it's the first annotation for the media file: if it is, the server creates a new table of contents and encodes the data profile into it; if not, the server encodes the data profile into an existing table of contents. The playable media file can be various formats like audio, video, audiovisual, slideshow, AVI, MP3, MP4, WMA, WAV, Flash, or MPEG.

• Independent Claim 8 (Article of Manufacture): This claim describes an article of manufacture, specifically a non-transitory computer readable medium containing computer readable program code. This code is designed to perform the steps outlined in Claim 1 for annotating playable media files in a social network. The steps include receiving a playable media file from a member, the member creating and providing an annotation and a data profile (with embedding location) to a network server, the network server embedding the annotation, and the network server determining if it's the first annotation to either create or update a table of contents with the annotation's data profile.

• Independent Claim 15 (Computer Program Product): This claim describes a computer program product encoded in a non-transitory computer readable medium. This product contains computer readable program code that, when executed by a programmable computer processor, causes the processor to perform the actions described in Claim 1 for annotating playable media files in a social network. These actions include receiving a playable media file and annotation from a member, providing a data profile for embedding, embedding the annotation, and managing the creation or updating of a table of contents based on whether it's the first annotation.

USPTO Database and CAFC 2026 Dockets Search:

A search for US9451001B2 on Google Patents indicates that the patent is "Active" and expires on 2034-04-14.

Regarding litigation, the Google Patents information for US9451001B2 shows several US cases filed in the California Northern District Court and a PTAB case (IPR2025-01404) filed (Procedural Termination). One of the PTAB cases, IPR2025-01404, was filed by GOOGLE LLC and ANDYOUTUBE, LLC, with an effective date of 2025-08-12. As of the current date (April 26, 2026), these cases are noted, but no specific CAFC 2026 docket results are provided that explicitly mention "CAFC 2026 docket US9451001". The provided information indicates District Court cases and a PTAB case, but not specifically Federal Circuit dockets for 2026. Therefore, I cannot definitively confirm any CAFC 2026 dockets for US9451001 with the provided search results.

US Patent 9451001, titled "Social networking with video annotation," has been involved in several litigation cases.

Here is a list of known litigation involving US Patent 9451001:

• Case Number: IPR2025-01404

  • Plaintiff(s): Google LLC; YouTube, LLC
  • Defendant(s): ART Research and Technology LLC
  • Jurisdiction: Patent Trial and Appeal Board (PTAB)
  • Filing Date: August 12, 2025
  • Outcome/Current Status: Pre-DI Dismissal (Procedural Termination). The Petitioner, Google LLC, requested institution of an inter partes review and cancellation of claims 1-21 of Patent 9,451,001 as unpatentable.

• Case Number: 24-cv-04898-AMO

  • Plaintiff(s): ART Research and Technology LLC
  • Defendant(s): Google, LLC and YouTube, LLC
  • Jurisdiction: U.S. District Court for the Northern District of California
  • Filing Date: Not explicitly stated in the provided text, but the decision was on September 29, 2025.
  • Outcome/Current Status: Google and YouTube's motion to dismiss ART's complaint for failure to state a claim was granted with leave to amend. The court found that the claims of the '001 patent (and other asserted patents) were unpatentable under 35 U.S.C. § 101 for being directed to an abstract idea without a necessary transformative inventive idea.

Proceedings overview

One AIA trial proceeding has been filed against US patent 9451001. This proceeding was terminated before institution, meaning no claims were challenged on the merits, and the patent owner's claims remain intact. This offers a defendant facing assertion of this patent a posture where the patent's validity has not been tested in an AIA trial.

IPR2025-01404 — Google LLC v. Art Research & Technology LLC

• Type: Inter Partes Review
• Filed: 2025-08-12
• Status: Terminated (Procedural Termination). This indicates the petition was withdrawn or denied institution on procedural or discretionary grounds on 2025-12-22, rather than reaching a merits decision.
• Judge panel: Jon M. Jurgovan (Author Judge) and Scott A. Daniels (Panel Judge). A full three-judge panel decision on the merits would not have been issued due to the procedural termination before institution.
• Petition grounds: Specific claims challenged, prior art asserted, and statutory bases (§ 102 / § 103 / § 112) are not publicly detailed for a procedurally terminated petition.
• Institution decision: Institution was denied on procedural grounds on 2025-12-22, coinciding with the termination date. While the exact reasoning for the procedural denial is not explicitly stated in the provided information, it likely relates to the Patent Trial and Appeal Board (PTAB) Director's discretionary denial framework or workload management policies, which underwent significant changes in early 2025. These changes made it materially harder to institute IPRs.
• Final Written Decision: Not issued, as the proceeding was terminated before reaching the trial stage.
• Settlement / termination: The proceeding was terminated on 2025-12-22 due to a "Procedural Termination." This type of termination commonly occurs when a petition is withdrawn or denied institution on discretionary grounds, without a determination on the merits.
• Appeal: No appeal of a Final Written Decision was possible, as no FWD was issued.
• Defensive value: The claims of US9451001 were not invalidated in this proceeding. For a defendant, this means the patent owner's claims remain intact as far as this specific IPR is concerned. The procedural termination suggests that the petitioner did not succeed in initiating a trial on the merits, potentially due to factors unrelated to the patent's inherent patentability, such as PTAB's discretionary denial policies.

Strategic summary

All claims of US9451001 are currently UNTESTED on their merits by an AIA trial proceeding. The single Inter Partes Review (IPR2025-01404) filed against the patent by Google LLC was terminated procedurally before an institution decision on the merits was reached. This outcome means that no claims of the patent were invalidated or confirmed as patentable by the PTAB.

Regarding the estoppel landscape, since IPR2025-01404 was procedurally terminated prior to institution, the statutory estoppel provisions of 35 U.S.C. § 315(e)(2) are unlikely to apply to Google LLC (or its privies) with respect to the grounds raised or that reasonably could have been raised. Estoppel typically attaches upon the issuance of a Final Written Decision. This suggests that the prior-art grounds that could have been asserted in this IPR may still be available for a future challenge, either by Google LLC if allowed, or by other defendants, subject to specific circumstances and PTAB's discretionary considerations.

The fact that the IPR was filed by Google LLC, with an "Inst. Date" coinciding with the "Term. Date" of 2025-12-22, indicates it was likely subject to the PTAB's new bifurcated institution regime implemented in early 2025. Under this regime, the Director first resolves discretionary factors, and institution might be denied based on workload management or other discretionary grounds (e.g., Fintiv factors) before a merits panel reviews the petition. This highlights a pattern of increased discretionary denials at the PTAB in 2025, making IPR institution more challenging.

Recommended next steps

There are no active PTAB proceedings concerning US9451001, and no claims have been invalidated by a Final Written Decision. The absence of an institution decision on the merits means that the patent's validity has not been "hardened" by surviving a full IPR trial, nor have any claims been canceled.

For a defendant currently being asserted against, this means all claims of US9451001 remain potentially vulnerable to a new IPR challenge if the statutory requirements are met and the petition can overcome the PTAB's current discretionary denial framework. It would be crucial to analyze the specific reasons for the procedural termination of IPR2025-01404 if those details become publicly available, as they could inform the strategy for a new petition. Without specific claim-level outcomes or an FWD, a defendant still faces the full scope of the asserted claims.

Inventors

• David Hirschfeld (ART RESEARCH AND TECHNOLOGY LLC)
• Barry Fernando (ART RESEARCH AND TECHNOLOGY LLC)
• Mark C. Phelps (ART RESEARCH AND TECHNOLOGY LLC)

Original assignee

The original assignee, ART RESEARCH AND TECHNOLOGY LLC, appears to be an operating company based on the Google Patents entry showing them as the applicant and current assignee. However, further investigation would be needed to determine if they ship a product embodying the claims and their primary line of business. Their current status, according to Google Patents, is "Active".

Assignment timeline

• 2015-01-06 (executed) / recorded 2015-01-06 — Reel 034645/0312
  • Conveyance: Assignment
  • Assignor: FERNANDO, BARRY; HIRSCHFELD, DAVID; PHELPS, MARK C.
  • Assignee: ART RESEARCH AND TECHNOLOGY, L.L.C.
  • Correspondent: ART RESEARCH AND TECHNOLOGY, L.L.C., 20860 N. 24TH AVE., SUITE 110, PHOENIX, ARIZONA 85027
  • Context: Internal reorg (assignment from individual inventors to the company)

Timeline diagram

timeline
    title Ownership of US 9451001
    2014 : Filed by ART RESEARCH AND TECHNOLOGY LLC
    2015 : Assigned to ART RESEARCH AND TECHNOLOGY, L.L.C. from inventors
    2016 : Issued

NPE / troll-pattern signals

1. Shell-entity transfer — Unclear. While the initial assignment is from the inventors to "ART RESEARCH AND TECHNOLOGY, L.L.C.", which could be seen as an internal reorg, without further information on the nature of "ART RESEARCH AND TECHNOLOGY, L.L.C." (e.g., whether it actively manufactures products or is purely a licensing entity), it is unclear if this represents a shell-entity transfer. The address provided for the correspondent is a physical office, not typically a registered agent service address.

2. Known asserter in the chain — Not present. ART RESEARCH AND TECHNOLOGY, L.L.C. is not explicitly listed as a known NPE on standard public directories (like those maintained by RPX or Unified Patents) in my training data.

3. Repeat correspondent across the chain — Not present. Only one assignment is recorded, so no recurrence is observed. The correspondent listed is "ART RESEARCH AND TECHNOLOGY, L.L.C." itself, indicating an internal filing.

4. Cascading transfers — Not present. Only one assignment is recorded.

5. Pre-litigation transfer — Unclear. The assignment was recorded on 2015-01-06. The patent was granted on 2016-09-20. Litigation records from Google Patents show cases filed in 2023 and 2024. The assignment significantly predates the first reported litigation, so this signal is not present in relation to the patent issuance and subsequent litigation.

6. Bankruptcy fire-sale — Not present. There is no indication in the provided data that the original assignee underwent bankruptcy proceedings.

7. Privateering — Unclear. There is no publicly available information in the provided patent text or Google Patents legal events to suggest privateering.

8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at a known defensive aggregator.

Verdict

NPE — insufficient data. There is only one recorded assignment for US9451001, which is from the individual inventors to the company ART RESEARCH AND TECHNOLOGY, L.L.C. prior to the patent's issuance (Reel 034645/0312, executed and recorded 2015-01-06). This typically represents an internal transfer or fulfillment of inventor assignment obligations. There are no subsequent assignments recorded that would indicate a transfer to a known NPE or exhibit other troll-pattern signals.

Verification can be done at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/

USPTO Database Search for US Patent 9451001

A search on the USPTO Patent Public Search website for patent number US9451001B2 confirms its existence and provides access to its full text and associated information. The patent is titled "Social networking with video annotation" and was issued on September 20, 2016, with a filing date of January 31, 2014. The current assignee is ART RESEARCH AND TECHNOLOGY LLC.

Most Relevant Prior Art for US Patent 9451001

The following patent citations are listed as prior art for US9451001B2. The potential anticipation under 35 U.S.C. § 102 is assessed based on the descriptions provided.

1. US6687878B1

   • Full Citation: US6687878B1 - Synchronizing/updating local client notes with annotations previously made by other clients in a notes database
   • Publication Date: 2004-02-03
   • Filing Date: 1999-03-15
   • Brief Description: This patent describes a system for synchronizing and updating local client notes with annotations previously made by other clients in a notes database.
   • Potential Anticipation (35 U.S.C. § 102): This patent potentially anticipates aspects of Claim 1, Claim 8, and Claim 15 related to the concept of receiving and managing annotations. Specifically, the synchronization and updating of "notes" (which can be considered a form of annotation) made by multiple clients (members of a network) in a shared database could be seen as a precursor to receiving annotations from another member and embedding them in a playable media file. The patent's focus on a "notes database" could also relate to the data profile and table of contents for managing annotations.

2. JP2009199500A

   • Full Citation: JP2009199500A - Digital content with annotation sharing system, intermediary server and terminal device
   • Publication Date: 2009-09-03
   • Filing Date: 2008-02-25
   • Brief Description: This patent describes a system for sharing digital content with annotations, involving an intermediary server and terminal devices.
   • Potential Anticipation (35 U.S.C. § 102): This reference is highly relevant as it explicitly discusses a "digital content with annotation sharing system." This directly aligns with the core inventive concept of US9451001B2. It potentially anticipates Claim 1, Claim 8, and Claim 15, particularly the aspects of receiving a playable media file (digital content) from a member, creating and sharing annotations, and using a network server (intermediary server) for this purpose. The details of embedding and table of contents would need further comparison to determine full anticipation.

3. US20090248833A1

   • Full Citation: US20090248833A1 - Location based content aggregation and distribution systems and methods
   • Publication Date: 2009-10-01
   • Filing Date: 2008-03-31
   • Brief Description: This patent application describes systems and methods for aggregating and distributing content based on location.
   • Potential Anticipation (35 U.S.C. § 102): While this patent deals with content aggregation and distribution, its relevance to US9451001B2 is less direct. It might broadly anticipate the sharing aspect of content within a network, but it doesn't specifically address video annotation or embedding annotations within playable media files. Therefore, it is less likely to anticipate the specific annotation and embedding claims (Claim 1, Claim 8, Claim 15) unless "content" is interpreted extremely broadly to include embedded annotations and the "location-based" aspect somehow relates to the "location in said Playable Media File" for embedding. Without more specific details on how location-based content aggregation relates to embedding annotations at specific points in playable media, its direct anticipatory effect on the core claims of US9451001B2 seems limited.

4. KR20100071359A

   • Full Citation: KR20100071359A - Apparatus and method for information search on the basis of tag and method for tag management
   • Publication Date: 2010-06-29
   • Filing Date: 2008-12-19
   • Brief Description: This patent describes an apparatus and method for information search based on tags and a method for tag management.
   • Potential Anticipation (35 U.S.C. § 102): This reference focuses on "tags" and "tag management" for information search. While "tags" can be considered a form of annotation or metadata, this patent does not explicitly describe embedding these tags within a playable media file at a specific location or creating a table of contents for them in the manner of US9451001B2. It might broadly touch upon the idea of associating additional information with media, but its direct anticipatory effect on Claim 1, Claim 8, and Claim 15 regarding embedded annotations and managing them in a table of contents is likely limited.

5. US20110063317A1

   • Full Citation: US20110063317A1 - Multifunction Multimedia Device
   • Publication Date: 2011-03-17
   • Filing Date: 2009-09-14
   • Brief Description: This patent application describes a multifunction multimedia device.
   • Potential Anticipation (35 U.S.C. § 102): This is a very broad description. Without more specific details on the "multifunction multimedia device" and whether its functionalities include social networking with embedded video annotations and associated table of contents management, it is difficult to assess its anticipatory potential. It's unlikely to directly anticipate the specific claims of US9451001B2 without explicit discussion of these features.

6. US20130046761A1

   • Full Citation: US20130046761A1 - Method and Apparatus for Social Tagging of Media Files
   • Publication Date: 2013-02-21
   • Filing Date: 2010-01-08
   • Brief Description: This patent application describes a method and apparatus for social tagging of media files.
   • Potential Anticipation (35 U.S.C. § 102): This reference is highly relevant due to its title "Method and Apparatus for Social Tagging of Media Files." "Tagging" can be considered a form of annotation, and "social tagging" implies a network context. This directly relates to the core of US9451001B2. It potentially anticipates Claim 1, Claim 8, and Claim 15, especially the parts about receiving a playable media file from a member, creating annotations (tags), and providing them within a social network. Further analysis would be needed to see if it specifically covers embedding the tags at a specific location within the playable media file and the dynamic creation/updating of a table of contents based on whether it's the first annotation.

7. KR20110136308A

   • Full Citation: KR20110136308A - Method of providing a user interface for sharing a comment and a mobile terminal using the same
   • Publication Date: 2011-12-21
   • Filing Date: 2010-06-14
   • Brief Description: This patent describes a method of providing a user interface for sharing a comment and a mobile terminal using the same.
   • Potential Anticipation (35 U.S.C. § 102): This reference focuses on sharing "comments" via a user interface on a mobile terminal. "Comments" can be a type of annotation. If these comments are associated with specific points in playable media files and are embedded or organized in a similar fashion to US9451001B2, then it could be highly relevant. The general concept of sharing comments (annotations) in a user interface is a foundational element. It potentially anticipates the broad idea of a social network member creating an annotation and providing it to a network server for sharing (Claim 1, Claim 8, Claim 15), but specific details on embedding within the media file at a location and table of contents management would need closer examination.

8. US20120284343A1

   • Full Citation: US20120284343A1 - Program Guide Based on Sharing Personal Comments about Multimedia Content
   • Publication Date: 2012-11-08
   • Filing Date: 2011-05-03
   • Brief Description: This patent application describes a program guide based on sharing personal comments about multimedia content.
   • Potential Anticipation (35 U.S.C. § 102): This reference is relevant in that it discusses "sharing personal comments about multimedia content," which aligns with the social networking and annotation aspects of US9451001B2. "Personal comments" can be seen as annotations. The "program guide" context might differ from direct embedding in a playable media file, but the sharing of timed comments could be an analogous concept. It potentially anticipates the broad concept of social sharing of annotations (Claim 1, Claim 8, Claim 15), but the specific embedding and table of contents features would require further comparison.

9. US20120317210A1

   • Full Citation: US20120317210A1 - Asynchronous Video Threads
   • Publication Date: 2012-12-13
   • Filing Date: 2011-06-13
   • Brief Description: This patent application describes asynchronous video threads, implying a discussion or commentary related to video content that can occur over time.
   • Potential Anticipation (35 U.S.C. § 102): This reference is highly relevant, especially concerning the "discussion thread" aspect of US9451001B2 (e.g., in Claim 5). "Asynchronous Video Threads" strongly suggests a system for comments or discussions tied to specific points in a video, which is a key feature of US9451001B2's discussion thread functionality. It would be important to determine if "asynchronous video threads" involve embedding comments at specific locations within the video and how they are managed (e.g., a table of contents). It very likely anticipates or renders obvious claims related to initiating and managing discussion threads within playable media.

10. US20140075317A1

    • Full Citation: US20140075317A1 - Digital content presentation and interaction
    • Publication Date: 2014-03-13
    • Filing Date: 2012-09-07
    • Brief Description: This patent application describes systems and methods for digital content presentation and interaction.
    • Potential Anticipation (35 U.S.C. § 102): This is a broad description. Similar to US20110063317A1, without more specific details on the "digital content presentation and interaction" and whether it includes social networking with embedded video annotations and associated table of contents management, its anticipatory potential is difficult to assess. It's unlikely to directly anticipate the specific claims of US9451001B2 without explicit discussion of these features.

Under 35 U.S.C. § 103, an invention cannot be patented if 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. This "obviousness" standard involves considering the scope and content of the prior art, the differences between the prior art and the claims, the level of ordinary skill in the pertinent art, and secondary considerations of non-obviousness. A combination of familiar elements according to known methods is likely to be obvious.

The claims of US Patent 9451001 revolve around receiving a playable media file in a social network, creating and providing an annotation along with a data profile indicating an embedding location to a network server, the server embedding the annotation, and managing a table of contents (creating if it's the first annotation, updating otherwise). The playable media file can be various formats (audio, video, etc.).

Let's consider combinations of prior art references cited in US9451001 that could render its claims obvious:

Combination 1: US6687878B1 (Real Time Image Ltd.) + US20120317210A1 (Microsoft Corporation)

• US6687878B1 (Synchronizing/updating local client notes with annotations previously made by other clients in a notes database): This patent describes synchronizing notes/annotations. While it focuses on "notes" rather than explicit "playable media files," the concept of associating annotations with content and sharing them among users in a networked environment is present. It addresses the idea of multiple users adding to a shared information space.

• US20120317210A1 (Asynchronous Video Threads): This reference explicitly deals with "asynchronous video threads," strongly implying the ability to associate comments or discussions with specific points in a video. The term "threads" suggests a sequential or time-based organization of content related to the video.

• Motivation to Combine: A person having ordinary skill in the art, seeking to enhance social interaction around media files, would be motivated to combine the annotation and multi-user collaboration aspects of US6687878B1 with the video-specific threading capabilities of US20120317210A1. It would be an obvious step to apply the concept of user-generated annotations from US6687878B1, which are linked to content and managed in a database, to the specific context of video files, as exemplified by the "video threads" in US20120317210A1. The "notes database" in US6687878B1 could readily be adapted to store data profiles and locations for annotations within playable media files, and the synchronization aspect aligns with updating a table of contents. The explicit mention of "video" in US20120317210A1 directly addresses the "Playable Media File" aspect of US9451001.

Combination 2: US20130046761A1 (Telefonaktiebolaget L M Ericsson) + US20120284343A1 (Lee David D)

• US20130046761A1 (Method and Apparatus for Social Tagging of Media Files): This reference focuses on "social tagging of media files." Tagging can be considered a form of annotation, where users add descriptive information to media. The "social" aspect implies a shared network environment.

• US20120284343A1 (Program Guide Based on Sharing Personal Comments about Multimedia Content): This patent describes sharing "personal comments about multimedia content," directly addressing the concept of user-generated textual or other comments associated with media. The "program guide" suggests a structured way to access and view this content and its associated comments.

• Motivation to Combine: A person of ordinary skill in the art would be motivated to combine the "social tagging" described in US20130046761A1 with the "sharing personal comments about multimedia content" from US20120284343A1. Tags, which are a form of annotation, naturally lend themselves to being embedded or associated with specific locations or segments of multimedia content, especially when considered in the context of shared personal comments. The idea of a "program guide" could easily be extended to a "table of contents" for annotations and comments within a playable media file, allowing for organized access to user-generated content associated with specific media points. The combination would result in a system where users can not only tag media socially but also attach more detailed comments, which are then organized for easy navigation, mirroring the table of contents and embedding features of US9451001.

General Obviousness Considerations for US9451001:

Many of the elements claimed in US9451001, such as social networking, sharing media files, creating annotations (text, audio, video), embedding content at specific locations within media, and organizing these annotations (e.g., in a table of contents), were individually known in the prior art. The core contribution appears to be the specific combination of these elements within a social network context, particularly the dynamic creation and updating of a table of contents for embedded annotations in playable media files.

However, given the cited prior art, a person skilled in the art (e.g., a software developer for social media platforms) would have understood the benefits of:

1. Enabling multi-user interaction with media: Social networks inherently foster sharing and collaborative interaction.
2. Contextualizing comments/annotations: Associating comments directly with specific points in time within a media file provides valuable context.
3. Organizing user-generated content: As the number of annotations grows, a mechanism like a table of contents becomes a natural and desirable feature for navigation and management.

The motivation to combine these known elements to create the system described in US9451001 would stem from the continuous drive in social networking to enhance user engagement, facilitate richer communication around shared content, and improve content discoverability and organization. The logical progression of features in social media and multimedia platforms would lead to the integration of these functionalities. The specific steps of determining if an annotation is the first and then creating or updating a table of contents are routine programming tasks for managing lists or data structures associated with a media file.