US 9043481

US Patent 9043481, titled "Managed access to media services," was issued to Digital River Inc. on May 26, 2015, from an application filed on October 22, 2013. The patent lists Gyuchang Jun, Kurt Huang, and Duane Kuroda as its inventors. The patent is currently expired, having reached its anticipated expiration date on June 8, 2025.

The abstract describes methods, apparatuses, and systems for managing account-based access to media services. A media access controller server validates a voucher for network content and then issues a token to permit access. A media access manager server subsequently validates this token and initiates a playlist-generation process at a publishing point, delivering the content to the user's media player. A custom plug-in on the media access manager can enforce publisher-defined terms of service, such as limiting the number of simultaneous streams per voucher or enforcing a time window for voucher use. Streams are terminated by the plug-in if the voucher's end time has passed.

A plain-language overview of the independent claims is as follows:

• Independent Claim 1 (Method): This claim describes a method for controlling access to online content. It involves first verifying a "voucher" that confirms authorization to access the content, where this voucher includes a unique identifier for the original transaction. After validating the voucher, a separate "token" is generated to grant actual access. A key feature is the ability to generate a first token for a first media player and a second token for a second media player, both derived from the same validated voucher and both containing the unique transaction ID from that voucher.
• Independent Claim 5 (Apparatus): This claim outlines a system (an "apparatus") designed to manage access to network content. It comprises a "validator" component to check the validity of a user's voucher (which includes a unique transaction ID). It also includes a "generator" component that creates a token, distinct from the voucher, which grants access to the content after the voucher is validated. This generator is configured to create multiple tokens—for example, one for a first media player and another for a second media player—with both tokens incorporating the unique transaction ID from the validated voucher. Additionally, the apparatus includes a "sender" component to transmit these tokens over a network to the media players.
• Independent Claim 9 (Apparatus): Similar to Claim 5, this claim also describes an apparatus for controlling access to network content. It includes a "validator" for confirming the validity of a voucher that contains a unique transaction ID. It features a "generator" configured to produce both a first token and a second token (each separate from the voucher) once the voucher is validated. These tokens authorize access to the content and are generated for a first and second media player, respectively, with both tokens containing the unique ID from the validated voucher. Finally, a "sender" component is included to send these first and second tokens over a network to their corresponding first and second media players.

As of April 26, 2026, there are no active dockets found for patent 9043481 in the CAFC 2026 database, which is consistent with its expired legal status.## US Patent 9043481: Managed Access to Media Services

Title: Managed access to media services

Assignee: Digital River Inc

Inventors: Gyuchang Jun, Kurt Huang, Duane Kuroda

Filing Date: 2013-10-22

Issue Date: 2015-05-26

Abstract:
US Patent 9043481 describes methods, apparatuses, and systems for providing account-based access to media services. The core process involves a media access controller server validating a voucher that represents a user's authorization for network content. Upon validation, the server issues a unique token that permits access to the content. Subsequently, a media access manager server validates this token and triggers a playlist-generation step at a publishing point, which then delivers the content to the user's media player. The patent also details the use of a custom plug-in within the media access manager to enforce publisher-defined terms of service, such as limiting the maximum number of simultaneous streams allowed by a single voucher or imposing a time window for the voucher's use. The plug-in is also responsible for terminating streams when a voucher's end time expires.

Plain-Language Overview of Independent Claims:

• Claim 1 (Method): This claim describes a process for managing access to online media. It involves two primary steps:

  1. Voucher Validation: Confirming that a user's "voucher" is legitimate, which serves as proof of authorization to access network content at a specific location (publishing point). This voucher contains a unique identification number (ID) linked to the transaction through which the user gained access.
  2. Token Generation: Creating a separate "token" that is distinct from the voucher, which then grants actual access to the content after the voucher has been validated. A key aspect is that this method allows for the generation of multiple tokens from a single validated voucher – for instance, a first token for one media player and a second token for another media player – with both generated tokens including the original unique transaction ID from the validated voucher.

• Claim 5 (Apparatus): This claim describes a physical or virtual system (an "apparatus") designed to control access to network content. The apparatus includes:

  1. A Validator: A component specifically configured to verify that a user's voucher, containing a unique transaction ID, is valid for accessing network content.
  2. A Generator: A component configured to create access tokens, which are separate from the voucher, once the voucher has been validated. This generator can produce a token for a first media player and a second token for a second media player, with both tokens incorporating the unique transaction ID from the validated voucher.
  3. A Sender: A component designed to transmit these generated tokens over a network to the respective media players.

• Claim 9 (Apparatus): This claim presents another apparatus for controlling access to network content, similar in concept to Claim 5 but emphasizing the generation and sending of distinct tokens to different players. It includes:

  1. A Validator: Configured to confirm the validity of a voucher, which includes a unique transaction ID, for accessing network content.
  2. A Generator: Configured to create two distinct tokens—a first token and a second token—both separate from the initial voucher. These tokens authorize access after the voucher is validated, with the first token being for a first media player and the second token for a second media player. Both of these generated tokens include the unique transaction ID from the validated voucher.
  3. A Sender: Configured to transmit the first token to the first media player and the second token to the second media player over a network.

Legal Status Note:
According to the provided patent information, US9043481 has an "Expired - Lifetime" legal status, with an "Anticipated expiration" date of 2025-06-08. Given the current date of April 26, 2026, the patent has indeed expired.

CAFC 2026 Dockets:
A search for US patent 9043481 in the CAFC 2026 dockets did not return any results. This indicates that there are no active cases involving this specific patent in the Court of Appeals for the Federal Circuit for the year 2026.

As of April 26, 2026, there is no known litigation specifically involving US Patent 9043481. Searches of patent litigation databases, including Unified Patents and PACER, as well as the CAFC website, did not return any cases for this patent number. The results found for "9043481" refer to various unrelated contexts such as financial reports, family history records, HP support community discussions, Hillphoenix refrigeration unit parts, and a ham radio callsign.

Proceedings overview

As of today, June 10, 2026, there are no AIA trial proceedings on file for US Patent 9043481. This means the patent has not been challenged through Inter Partes Review (IPR), Post-Grant Review (PGR), or Covered Business Method (CBM) review at the Patent Trial and Appeal Board (PTAB). For a defendant, this signifies that the patent claims have not been subjected to PTAB scrutiny, and therefore, their validity remains untested in this forum.

Strategic summary

The absence of any PTAB proceedings means that all claims of US9043481 (Claims 1-15) are currently untested in an AIA trial. There are no canceled, sustained, or narrowed claims as a result of PTAB challenges.

Regarding the estoppel landscape, since no PTAB proceedings have occurred, there are no estoppel bars under 35 U.S.C. § 315(e)(2) for any potential petitioner. All prior-art grounds that could be raised under §§ 102 or 103 (for IPR) or any ground of invalidity including §§ 101, 102, 103, and 112 (for PGR or CBM, if applicable) remain available to a challenger.

There is no pattern of PTAB activity to analyze, as no petitions have been filed against this patent. The lack of PTAB challenges for an issued patent, especially one that expired in June 2025, can sometimes indicate that it was not heavily asserted in litigation, or that potential challengers did not find compelling grounds to initiate a review, or simply that the patent owner chose not to enforce it aggressively enough to provoke such actions.

Recommended next steps

Since there is no PTAB activity for US Patent 9043481, a defendant facing assertion of this patent would need to initiate a new PTAB proceeding if they wish to challenge its validity through this avenue. However, given that the patent has expired (on June 8, 2025), the opportunity for new Post-Grant Review (PGR) or Covered Business Method (CBM) reviews is likely closed, as these typically have strict timeframes after patent issuance (9 months for PGR and CBM, with CBM being a temporary program that ended in 2020). While IPRs can be filed later, they are generally initiated within one year of being served with a complaint alleging infringement, and only challenge validity on grounds of novelty or obviousness based on patents or printed publications. The expiration of the patent also means that its value for assertion is significantly diminished, as no new infringement can occur.

Inventors

• Gyuchang Jun (Digital River Inc.)
• Kurt Huang (Digital River Inc.)
• Duane Kuroda (Digital River Inc.)

(Employer at time of filing is inferred from the original assignee, Digital River Inc., as is typical for patent applications. No information suggests otherwise.)

Original assignee

The original assignee is Digital River Inc. Digital River is a global e-commerce company that provides online storefronts, payment processing, and digital marketing services for software and game publishers. Their primary line of business involves facilitating online sales and distribution for other companies. As of 2026, Digital River Inc. is still operating.

Assignment timeline

To reconstruct the full assignment record, I will use the USPTO Assignment Center.

• 2005-06-08 (executed) / recorded 2015-04-14 — Reel 035402/0416

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: JUN, GYUCHANG; HUANG, KURT H.; KURODA, DUANE
  • Assignee: BITPASS, INC., CALIFORNIA
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Transfer of inventor's interest to Bitpass, Inc.

• 2007-01-22 (executed) / recorded 2015-04-14 — Reel 035402/0500

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: BITPASS, INC.
  • Assignee: DIGITAL RIVER, INC., MINNESOTA
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Transfer of patent rights from Bitpass, Inc. to Digital River, Inc. This likely represents Digital River acquiring Bitpass or its assets.

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

  • Conveyance: FIRST LIEN GRANT OF SECURITY INTEREST PATENTS
  • Assignor: DIGITAL RIVER, INC.
  • Assignee: MACQUARIE US TRADING LLC, ILLINOIS
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Grant of a security interest, likely as collateral for a loan or financing arrangement.

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

  • Conveyance: SECURITY INTEREST
  • Assignor: DIGITAL RIVER, INC.
  • Assignee: CORTLAND CAPITAL MARKET SERVICESLLC, AS COLLATERAL AGENT, ILLINOIS
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Grant of a security interest, likely as collateral for a loan or financing arrangement.

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

  • Conveyance: GRANT OF SECURITY INTEREST PATENTS
  • Assignor: DIGITAL RIVER, INC.; DIGITAL RIVER MARKETING SOLUTIONS, INC.; DR APAC, LLC; AND OTHERS
  • Assignee: CERBERUS BUSINESS FINANCE AGENCY, LLC, AS THE COLLATERAL AGENT, NEW YORK
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Grant of a security interest, likely as collateral for a loan or financing arrangement.

• 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., MINNESOTA
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Release of the security interest previously granted to Macquarie US Trading LLC, indicating the associated obligation was satisfied.

• 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., MINNESOTA
  • Correspondent: Not specified in Google Patents, will attempt to find on USPTO.
  • Context: Release of the security interest previously granted to Cortland Capital Market Services LLC, indicating the associated obligation was satisfied.

Timeline diagram

timeline
    title Ownership of US 9043481
    2004 : Priority Date
    2005 : Inventors to Bitpass Inc
    2007 : Bitpass to Digital River Inc
    2013 : Application filed
    2015 : Security interest to Macquarie
         : Security interest to Cortland
         : Issued
    2021 : Security interest to Cerberus
         : Release by Macquarie
         : Release by Cortland
    2025 : Expired

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The transfers involve operating companies (Bitpass, Digital River) and financial institutions for security interests. There's no clear evidence of a transfer to a licensing-only shell entity.
2. Known asserter in the chain — Not present. None of the listed assignees (Digital River Inc., Bitpass Inc., Macquarie US Trading LLC, Cortland Capital Market ServicesLLC, Cerberus Business Finance Agency, LLC) are recognized as high-frequency patent assertion entities (NPEs) based on common public lists.
3. Repeat correspondent across the chain — Unclear. The Google Patents legal events record does not provide correspondent information. A direct USPTO Assignment search would be needed to determine this.
4. Cascading transfers — Not present. While there are multiple security interest recordings in 2015 and 2021, these are typical financial transactions rather than a rapid succession of ownership transfers between different entities for the purpose of assertion.
5. Pre-litigation transfer — Not present. The patent expired in 2025, and there is no indication of litigation.
6. Bankruptcy fire-sale — Not present. Digital River Inc. appears to be an active, operating company. The security interests and their releases are normal business financing activities, not indicative of bankruptcy sales.
7. Privateering — Not present. No evidence suggests Digital River Inc. transferred the patent to an NPE for assertion against competitors.
8. Defensive aggregator (anti-NPE) — Not present. The chain does not end at any known defensive aggregators.

Verdict

Insufficient data. While the full assignment chain from Google Patents legal events shows various transfers and security interests, crucial information for determining NPE patterns, such as correspondent attorneys and detailed contexts beyond what Google provides (e.g., product lines of Bitpass Inc.), is not readily available. Without a direct USPTO Assignment Center search to retrieve correspondent details and further investigation into the business activities of Bitpass Inc., it is not possible to confidently identify NPE patterns. The current chain primarily reflects the original assignee's ownership and financing activities.

Link to USPTO Assignment Center search for US9043481

To identify the most relevant prior art for US patent 9043481, I will examine the patent citations listed within the patent document. The "Citations" section of the patent on Google Patents provides a comprehensive list of both patent and non-patent literature considered by the examiner. I will focus on the patent citations for potential anticipation under 35 U.S.C. § 102.

Here's an analysis of the patent citations listed for US9043481:

Patent Citations and Potential Anticipation

For each cited patent, I will provide the full citation, publication/filing date, a brief description of its relevance based on its title and abstract (where available within the provided patent text), and an assessment of which claim(s) of US9043481 it potentially anticipates under 35 U.S.C. § 102. Anticipation under 35 U.S.C. § 102 occurs when a single prior art reference discloses every element of a claimed invention.

1. US20010045451A1

   • Full Citation: US20010045451A1, "Method and system for token-based authentication"
   • Publication Date: 2001-11-29
   • Filing Date: 2000-02-28
   • Brief Description: This patent application describes a method and system for token-based authentication. Given the title, it likely involves using tokens for secure access, a core concept in US9043481.
   • Potential Anticipation: This reference could potentially anticipate aspects of Claims 1, 5, and 9 related to the generation and use of tokens for access control, particularly if it details the creation of unique tokens based on an initial authorization and for multiple devices. The specific details of how its tokens are generated and what information they contain would be critical.

2. US6360254B1

   • Full Citation: US6360254B1, "System and method for providing secure URL-based access to private resources"
   • Publication Date: 2002-03-19
   • Filing Date: 1998-09-15
   • Brief Description: This patent focuses on providing secure access to private resources using URL-based methods. This is highly relevant as US9043481 utilizes URLs for publishing points and includes tokens within URLs.
   • Potential Anticipation: This could potentially anticipate aspects of Claims 1, 5, and 9, particularly concerning secure access to network content via URLs and the mechanisms for controlling that access. The generation of a token including a URL for a publishing point (as mentioned in claim 2) could be anticipated if this patent details similar methods.

3. US6484197B1

   • Full Citation: US6484197B1, "Filtering incoming e-mail"
   • Publication Date: 2002-11-19
   • Filing Date: 1998-11-07
   • Brief Description: This patent pertains to filtering incoming email.
   • Potential Anticipation: Based on the title, this patent seems less directly related to the core token-based media access control of US9043481. It is unlikely to anticipate the claims unless there are hidden details about token-based content access within the email filtering context.

4. US20020177433A1

   • Full Citation: US20020177433A1, "Methods and apparatus for restricting access of a user using a cellular telephone"
   • Publication Date: 2002-11-28
   • Filing Date: 2001-05-24
   • Brief Description: This patent application describes methods and apparatus for restricting user access, specifically in the context of cellular telephones.
   • Potential Anticipation: This could potentially anticipate the general concept of restricting access to content, but its focus on cellular telephones might distinguish it from the broader media player context of US9043481. If it describes using vouchers and generating multiple tokens for different devices from a single transaction, it could anticipate Claims 1, 5, and 9.

5. US6505300B2

   • Full Citation: US6505300B2, "Method and system for secure running of untrusted content"
   • Publication Date: 2003-01-07
   • Filing Date: 1998-06-12
   • Brief Description: This patent relates to secure execution of untrusted content.
   • Potential Anticipation: While it addresses security, its primary focus on "untrusted content" may differentiate it from US9043481's "managed access to media services" where content is generally trusted but access is controlled based on payment or subscription. It might anticipate general security aspects but is less likely to anticipate the specific voucher/token and multi-device access elements of the independent claims.

6. US20030037070A1

   • Full Citation: US20030037070A1, "Streaming media security system"
   • Publication Date: 2003-02-20
   • Filing Date: 2001-07-31
   • Brief Description: This patent application describes a security system specifically for streaming media. This is highly relevant to US9043481, which deals with managed access to network media, often streaming.
   • Potential Anticipation: This could significantly anticipate Claims 1, 5, and 9 if it describes a similar voucher/token system for granting account-based access to streaming media across multiple devices. The phrase "streaming media security system" suggests a direct overlap in the field of invention.

7. US20030061250A1

   • Full Citation: US20030061250A1, "Random number generating circuit"
   • Publication Date: 2003-03-27
   • Filing Date: 2001-09-26
   • Brief Description: This patent application describes a random number generating circuit.
   • Potential Anticipation: This patent appears unrelated to the core aspects of managed media access and token generation as described in US9043481, unless the random number generation is specifically tied to the security or uniqueness of the tokens in a way not immediately apparent from the title. It is unlikely to anticipate the independent claims.

8. US20030093539A1

   • Full Citation: US20030093539A1, "Message generation"
   • Publication Date: 2003-05-15
   • Filing Date: 2001-11-13
   • Brief Description: This patent application describes message generation.
   • Potential Anticipation: Similar to the previous, this patent's general title makes it seem broadly unrelated to the specific technical problem addressed by US9043481. It is unlikely to anticipate the independent claims.

9. US20030099353A1

   • Full Citation: US20030099353A1, "Method of printing a document"
   • Publication Date: 2003-05-29
   • Filing Date: 2001-10-13
   • Brief Description: This patent application describes a method of printing a document.
   • Potential Anticipation: This patent appears entirely unrelated to the managed access to media services of US9043481 and is highly unlikely to anticipate any of its claims.

10. US20030120943A1

    • Full Citation: US20030120943A1, "System and method for controlling the use and duplication of digital content distributed on removable media"
    • Publication Date: 2003-06-26
    • Filing Date: 2001-11-15
    • Brief Description: This patent application describes controlling the use and duplication of digital content on removable media.
    • Potential Anticipation: This reference is relevant to controlling digital content, similar to US9043481. However, its focus on "removable media" might distinguish it from network-streamed or downloaded content. If it discusses a voucher/token system for enabling multi-device access from a single authorization, it could anticipate Claims 1, 5, and 9.

11. US6718328B1

    • Full Citation: US6718328B1, "System and method for providing controlled and secured access to network resources"
    • Publication Date: 2004-04-06
    • Filing Date: 2000-02-28
    • Brief Description: This patent describes a system and method for providing controlled and secured access to network resources. This is broadly aligned with the subject matter of US9043481.
    • Potential Anticipation: This patent has a strong potential to anticipate elements of Claims 1, 5, and 9, particularly regarding controlled and secured access to network resources. The critical details would be whether it employs a voucher/token system, a unique transaction ID in those tokens, and the ability to generate multiple tokens for different devices from a single authorization.

12. US6779115B1

    • Full Citation: US6779115B1, "Portable device using a smart card to receive and decrypt digital data"
    • Publication Date: 2004-08-17
    • Filing Date: 2000-02-18
    • Brief Description: This patent describes a portable device using a smart card for receiving and decrypting digital data.
    • Potential Anticipation: While dealing with digital data and access, the explicit reliance on a "smart card" as the authorization mechanism might differentiate it from the voucher/token system of US9043481, which seems more software-based. It is unlikely to anticipate the specific claims unless smart cards are considered equivalent to "vouchers" in a broad sense, and multi-device access from a single authorization is detailed.

13. US20040243475A1

    • Full Citation: US20040243475A1, "Method and telecommunication network for delivering and charging for services"
    • Publication Date: 2004-12-02
    • Filing Date: 2001-10-22
    • Brief Description: This patent application describes a method and telecommunication network for delivering and charging for services.
    • Potential Anticipation: This reference could anticipate the "transaction" aspect of the voucher in US9043481. If it details how an initial transaction leads to an authorization mechanism that then allows multiple access points (similar to the voucher/token for multiple media players), it could anticipate Claims 1, 5, and 9.

14. US6868403B1

    • Full Citation: US6868403B1, "Secure online music distribution system"
    • Publication Date: 2005-03-15
    • Filing Date: 1998-02-06
    • Brief Description: This patent describes a secure online music distribution system. This is very closely related to "managed access to media services" for network content.
    • Potential Anticipation: This patent has a high potential to anticipate Claims 1, 5, and 9, especially if it details a system that uses an initial authorization (like a voucher) to generate distinct access credentials (like tokens) for multiple playback devices (media players) based on a single transaction. The field of invention is almost identical.

15. US20050060389A1

    • Full Citation: US20050060389A1, "System and method for evaluating a capacity of a streaming media server for supporting a workload"
    • Publication Date: 2005-03-17
    • Filing Date: 2003-09-12
    • Brief Description: This patent application describes a system and method for evaluating the capacity of a streaming media server.
    • Potential Anticipation: While related to streaming media servers, its focus on "capacity evaluation" is different from access control. It is unlikely to anticipate the core claims of US9043481, which deal with the authorization and token-based access mechanism.

16. US6948061B1

    • Full Citation: US6948061B1, "Method and device for performing secure transactions"
    • Publication Date: 2005-09-20
    • Filing Date: 2000-09-20
      Brief Description: This patent describes a method and device for performing secure transactions.
    • Potential Anticipation: This reference could anticipate the "transaction" aspect of the voucher in US9043481. If it elaborates on how a secure transaction leads to authorization and subsequent access for multiple entities or devices, it could anticipate Claims 1, 5, and 9.

17. US20060059346A1

    • Full Citation: US20060059346A1, "Authentication with expiring binding digital certificates"
    • Publication Date: 2006-03-16
    • Filing Date: 2004-09-14
    • Brief Description: This patent application describes authentication using expiring digital certificates. The concept of an "expiring" element is relevant to the "time window" for tokens/vouchers in US9043481.
    • Potential Anticipation: This could potentially anticipate aspects of Claims 2, 6, 10, 11, 13, and 14, which involve a "time window during which the token is valid" or a "timestamp identifying when the voucher expires." If the digital certificates function similarly to tokens derived from a primary authorization and can be used on multiple devices, it could also anticipate Claims 1, 5, and 9.

18. US20060085862A1

    • Full Citation: US20060085862A1, "Method and system for authorizing multimedia multicasting"
    • Publication Date: 2006-04-20
    • Filing Date: 2004-10-05
    • Brief Description: This patent application describes a method and system for authorizing multimedia multicasting. "Multimedia" and "authorizing" are key terms for US9043481.
    • Potential Anticipation: This could anticipate aspects of Claims 1, 5, and 9, especially if "multicasting" implies simultaneous access to content by multiple authorized users/devices based on an initial authorization, similar to the multi-player aspect of US9043481. The details of the authorization mechanism would be crucial.

19. US20060095779A9

    • Full Citation: US20060095779A9, "Uniform resource locator access management and control system and method"
    • Publication Date: 2006-05-04
    • Filing Date: 2001-08-06
    • Brief Description: This patent application describes a system and method for URL access management and control. This is directly relevant given US9043481's use of URLs for publishing points and tokens.
    • Potential Anticipation: This patent has a high potential to anticipate Claims 1, 5, and 9, particularly concerning the management and control of access to resources via URLs. If it details a voucher/token system for multi-device access, it would be highly relevant.

20. US20060184997A1

    • Full Citation: US20060184997A1, "Control for inviting an unauthenticated user to gain access to display of content that is otherwise accessible with an authentication mechanism"
    • Publication Date: 2006-08-17
    • Filing Date: 2004-01-29
    • Brief Description: This patent application describes a system for allowing unauthenticated users to gain access to content that typically requires authentication.
    • Potential Anticipation: This could potentially anticipate the initial stages of gaining access to content, but its focus on "unauthenticated users" may distinguish it from US9043481's focus on a pre-validated "voucher" representing authorization. However, if the underlying authentication mechanism involves a voucher/token system for multiple devices, it could be relevant to Claims 1, 5, and 9.

21. US20060190616A1

    • Full Citation: US20060190616A1, "System and method for aggregating, delivering and sharing audio content"
    • Publication Date: 2006-08-24
    • Filing Date: 2005-02-04
    • Brief Description: This patent application describes a system and method for aggregating, delivering, and sharing audio content.
    • Potential Anticipation: This is relevant to "media services" and "network content" as it deals with audio content delivery. If it details an access control mechanism involving vouchers/tokens for sharing content across multiple devices based on a single authorization, it could anticipate Claims 1, 5, and 9.

22. US20060225138A1

    • Full Citation: US20060225138A1, "End-to-end digital media entitlement system"
    • Publication Date: 2006-10-05
    • Filing Date: 2005-04-02
    • Brief Description: This patent application describes an "end-to-end digital media entitlement system," which is highly relevant to "managed access to media services."
    • Potential Anticipation: This patent has a very high potential to anticipate Claims 1, 5, and 9. "Entitlement system" strongly suggests a mechanism for granting and controlling access to digital media. If it implements a voucher/token system with unique transaction IDs to enable access on multiple devices, it would be a very strong prior art reference.

23. US20070219908A1

    • Full Citation: US20070219908A1, "Providing syndicated media to authorized users"
    • Publication Date: 2007-09-20
    • Filing Date: 2006-03-02
    • Brief Description: This patent application describes providing syndicated media to authorized users. The concept of "syndicated media" and "authorized users" directly aligns with US9043481's focus.
    • Potential Anticipation: This has a high potential to anticipate Claims 1, 5, and 9. "Syndicated media" could imply distribution to multiple points, and "authorized users" points to an access control mechanism. If this system uses a voucher/token scheme for multi-device access from a single user authorization, it would be highly relevant.

24. US20080183628A1

    • Full Citation: US20080183628A1, "System for management of alternatively priced transactions on network"
    • Publication Date: 2008-07-31
    • Filing Date: 1997-03-07
    • Brief Description: This patent application describes a system for managing transactions with alternative pricing on a network.
    • Potential Anticipation: This could potentially anticipate the "transaction" aspect of the voucher. However, its focus on "alternatively priced transactions" might differentiate it from the direct access control mechanism of US9043481, unless the transaction management also includes a voucher/token system for multi-device media access.

25. US7454356B2

    • Full Citation: US7454356B2, "Completely anonymous purchasing of goods on a computer network"
    • Publication Date: 2008-11-18
    • Filing Date: 2000-10-24
    • Brief Description: This patent describes anonymous purchasing of goods on a computer network.
    • Potential Anticipation: While dealing with transactions on a network, the "anonymous purchasing" aspect does not directly align with the identified user and account-based access of US9043481. It is unlikely to anticipate the core claims.

26. US7603469B2

    • Full Citation: US7603469B2, "Provisioning aggregated services in a distributed computing environment"
    • Publication Date: 2009-10-13
    • Filing Date: 2002-01-15
    • Brief Description: This patent describes provisioning aggregated services in a distributed computing environment.
    • Potential Anticipation: "Aggregated services" could potentially involve media services, and a "distributed computing environment" could relate to multiple publishing points and media players. If this patent details an authorization system that grants access to these aggregated services via tokens derived from a primary authorization and enables multi-device access, it could anticipate Claims 1, 5, and 9.

27. US20090287837A1

    • Full Citation: US20090287837A1, "Information record infrastructure, system and method"
    • Publication Date: 2009-11-19
    • Filing Date: 2000-07-06
    • Brief Description: This patent application describes an information record infrastructure, system, and method.
    • Potential Anticipation: This general title does not suggest a direct relation to media access control. It is unlikely to anticipate the independent claims without more specific details about its application to content access and token generation.

28. US7962415B2

    • Full Citation: US7962415B2, "Performing automatically authorized programmatic transactions"
    • Publication Date: 2011-06-14
    • Filing Date: 2004-07-19
    • Brief Description: This patent describes performing automatically authorized programmatic transactions.
    • Potential Anticipation: This could potentially anticipate the "transaction" aspect and the automated nature of authorization in US9043481. If the "programmatic transactions" lead to the issuance of tokens for multi-device access to media, it could anticipate Claims 1, 5, and 9.

29. US8051491B1

    • Full Citation: US8051491B1, "Controlling use of computing-related resources by multiple independent parties"
    • Publication Date: 2011-11-01
    • Filing Date: 2007-12-10
    • Brief Description: This patent describes controlling the use of computing resources by multiple independent parties. "Multiple independent parties" could be analogous to multiple media players of a single user.
    • Potential Anticipation: This has a strong potential to anticipate Claims 1, 5, and 9 if it details a mechanism for authorizing access to resources (e.g., media content) for multiple entities (e.g., media players) from a single initial authorization, using tokens with unique transaction IDs.

30. US8095972B1

    • Full Citation: US8095972B1, "Secure authentication for web-based applications"
    • Publication Date: 2012-01-10
    • Filing Date: 2008-10-06
    • Brief Description: This patent describes secure authentication for web-based applications.
    • Potential Anticipation: This could anticipate the authentication aspects of the voucher validation and token generation. If it details a system that issues tokens based on an initial authentication, and these tokens can enable access to content on multiple devices, it could anticipate Claims 1, 5, and 9.

31. US8281136B2

    • Full Citation: US8281136B2, "Techniques for key distribution for use in encrypted communications"
    • Publication Date: 2012-10-02
    • Filing Date: 2005-10-21
    • Brief Description: This patent describes techniques for key distribution in encrypted communications.
    • Potential Anticipation: While encryption is a component of security, the core of US9043481 is access management using vouchers and tokens, not just key distribution. It's unlikely to anticipate the independent claims unless the "keys" function directly as multi-device access tokens tied to a transaction ID.

32. US8316091B2

    • Full Citation: US8316091B2, "Content management for wireless digital media frames"
    • Publication Date: 2012-11-20
    • Filing Date: 2008-12-01
    • Brief Description: This patent describes content management for wireless digital media frames.
    • Potential Anticipation: This is relevant to "media services" and "network content." The term "content management" suggests access control. If it details a system for managing access to content on multiple wireless digital media frames using a voucher-like initial authorization and derived tokens, it could anticipate Claims 1, 5, and 9.

33. US8333317B2

    • Full Citation: US8333317B2, "System and method for authenticating the proximity of a wireless token to a computing device"
    • Publication Date: 2012-12-18
    • Filing Date: 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: This patent's focus on "proximity authentication" for a "wireless token" seems distinct from the network-based, non-proximity-dependent token system of US9043481. While it uses "token," the context is different, making it unlikely to anticipate the independent claims.

34. US8447858B1

    • Full Citation: US8447858B1, "System for improving quality of service for wireless LANS"
    • Publication Date: 2013-05-21
    • Filing Date: 2005-11-18
    • Brief Description: This patent describes a system for improving quality of service for wireless LANs.
    • Potential Anticipation: This patent appears unrelated to the core access control mechanisms of US9043481. It is unlikely to anticipate the independent claims.

35. US8566461B1

    • Full Citation: US8566461B1, "Managed access to media services"
    • Publication Date: 2013-10-22
    • Filing Date: 2004-06-09
    • Brief Description: This patent, "Managed access to media services," has the exact same title as US9043481. It also shares the same priority date of 2004-06-09, suggesting it is a related or continuation patent.
    • Potential Anticipation: Given the identical title and priority date, US8566461B1 is highly likely to be a divisional, continuation, or continuation-in-part of the same original application that led to US9043481. Therefore, it would likely disclose much of the same subject matter and would be considered prior art only if its effective filing date (which is the same as the priority date) is earlier and it discloses elements not present in a prior common application. However, as it is a related patent from the same "family" of applications, it would likely be considered by the examiner during prosecution rather than acting as anticipating prior art against the invention itself, but rather establishing the inventive step. If it has an earlier publication date and discloses all elements of any claim of US9043481, it could anticipate that claim. However, its filing date is later than US9043481's earliest priority date, meaning it is not anticipatory prior art but rather a related patent.

Most Relevant Prior Art

Based on the titles and brief descriptions, the most relevant prior art references for US9043481 are those that directly address secure access to network content, streaming media, or the distribution of digital media with authorization controls. These include:

• US20030037070A1: "Streaming media security system" - Directly addresses security for streaming media, which is a core application of US9043481.
• US6868403B1: "Secure online music distribution system" - Very similar field of invention, focusing on secure online content distribution.
• US20060095779A9: "Uniform resource locator access management and control system and method" - Directly relevant due to US9043481's reliance on URLs and access management.
• US20060225138A1: "End-to-end digital media entitlement system" - The term "entitlement system" strongly suggests a comprehensive mechanism for managing access to digital media.
• US6718328B1: "System and method for providing controlled and secured access to network resources" - Broadly covers controlled and secured access, which is fundamental to US9043481.
• US8051491B1: "Controlling use of computing-related resources by multiple independent parties" - Potentially highly relevant if it describes multi-device access from a single authorization.

To definitively determine anticipation under 35 U.S.C. § 102, a detailed claim-by-claim analysis comparing the full disclosures of these prior art documents against the independent claims of US9043481 would be required. This would involve examining whether each and every element of the independent claims (Claim 1, 5, and 9), including the unique ID, the generation of separate and distinct tokens, and the capability for multiple media players from a single voucher, is explicitly disclosed in a single one of these prior art references.

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.