PTAB

IPR2013-00335

Mobotix Corp v. E Watch Corp

Key Events

Petition

petition Intelligence

Title: Multimedia Network Appliances for Security and Surveillance Applications
Brief Description: The ’429 patent discloses a network-based security appliance designed to capture, process, and transmit multimedia data. The invention describes an integrated system comprising video and audio sensors, dedicated processors for MPEG (motion video) and JPEG (still image) compression, a multiplexer to combine the different data streams, and a network interface for transmission.

Prior Art Relied Upon: Seeley (Patent 6,069,655).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Seeley, which discloses an advanced video security system, teaches every element of independent claim 1. Seeley's system includes cameras (sensor component), a site control unit or SCU (processor), and a terminal adapter (network interface) for transmitting compressed images over a digital network (ISDN). Petitioner contended that Seeley's "video compression module 50" and "frame compression unit 44" correspond directly to the claimed MPEG and JPEG compressors, respectively, asserting that a person of ordinary skill in the art (POSITA) would have found it obvious to implement these generic modules using the well-known MPEG and JPEG standards. The petition further mapped Seeley's microphone and audio processing modules to the audio sensor and compressor limitations and identified Seeley's "video out module 46" as the claimed multiplexer for combining video and audio signals.
- Expectation of Success: Petitioner asserted that a POSITA would have a high expectation of success in applying the specific MPEG and JPEG compression standards to Seeley's system. This was because MPEG and JPEG were among a limited number of universally accepted and predictable standards for video and still image compression at the time of the invention.

Prior Art Relied Upon: Seeley (Patent 6,069,655) and Katata (an August 1999 IEEE technical paper titled “MPEG-4 Camera for use with Internet”).
Core Argument for this Ground:
- Prior Art Mapping: As an alternative position, Petitioner argued that to the extent Seeley alone was deemed insufficient, the combination with Katata rendered the claims obvious. Katata discloses an MPEG-4 camera for internet use that explicitly includes components Petitioner argued were obvious implementations in Seeley. Specifically, Katata teaches an analog-to-digital (A/D) converter, an MPEG-4 video compressor, a JPEG codec for still images, and an audio A/D converter, directly mapping to key limitations of claim 1.
- Motivation to Combine: Petitioner argued a POSITA would combine the teachings of Seeley and Katata because Seeley itself suggests its camera units are modular and can be replaced with other camera types without affecting overall system performance. Therefore, modifying Seeley’s system to incorporate the advanced, internet-ready features of the Katata camera would have been a simple, well-known substitution to achieve the predictable benefits of improved compression and network capability.
- Expectation of Success: The proposed combination was presented as a predictable substitution of one known camera type for another to predictably gain the known benefits of Katata's features.

Prior Art Relied Upon: Mobotix INTERNET-Vision-Systems brochure (publicly distributed at the CeBIT 2000 trade show).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that the Mobotix Brochure, which describes a commercial surveillance camera, discloses all limitations of claim 1. The brochure teaches a camera appliance with digital CMOS image sensors, an internal image processor, and integrated network interfaces (ISDN and Ethernet). Petitioner mapped the claimed MPEG compressor to the brochure's stated support for the H.320 videophone protocol, which includes MPEG-like video codecs (H.261/H.262). The claimed JPEG compressor was mapped to the brochure's explicit support for the JPEG format. Petitioner argued that the brochure's disclosure of transmitting live video and still images simultaneously would have made the use of a multiplexer obvious to a POSITA.
- Key Aspects: This ground relied on a commercial product brochure, demonstrating that the claimed combination of features was known in the marketplace before the ’429 patent's filing date.
Additional Grounds: Petitioner asserted additional obviousness challenges, including for claims 1-3 over Ryuichi (Japanese Patent Publication No. H07-46557) alone, and for various claims over the combination of Seeley and Fernandez (Patent 6,697,103), which added teachings on wireless networks and integrated non-imaging sensors.

Petitioner requests institution of an inter partes review and cancellation of claims 1-14, 22, 26-28, 32-35, 38, 44-49, 51, and 65 of the ’429 patent as unpatentable.