In re WAG Acquisition, LLC

In re WAG Acquisition, LLC The Federal Circuit affirmed the Board’s finding that Hill anticipated claims 1 and 4. Substantial evidence supported the Board’s findings on the claimed transmission requests, serial-number tracking in the player buffer, and receipt at a rate faster than playback. The decision underscores that broad media-buffering claim language can read on aggregate data-transfer functionality in prior art, even where the patent owner urges narrower implementation-specific readings. Affirmed. The disputed claims covered a media player that requests numbered media data elements, stores them in a buffer, tracks the serial number of the last received and stored element, and receives a predetermined number of elements faster than playback. For limitation 1.i.1, substantial evidence supported the Board’s finding that Hill disclosed requests for frames identified by global frame number, including where sources were accessed via a network server or Internet site. For limitation 1.g, the court held the Board reasonably found that Hill’s buffer manager maintained the relevant frame-number record needed to determine which frames to request next. For dependent claim 4, the court rejected WAG’s narrow reading that each individual data element had to be sent faster than playback; the claim covered an overall receipt rate faster than the playback rate. The nonprecedential opinion affirmed the Board’s anticipation ruling in full. § 102 claim construction non-precedential § 102 claim construction non-precedential § 102 claim construction non-precedential