PTAB

IPR2013-00337

Mobotix Corp v. E Watch Corp

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1. Case Identification

2. Patent Overview

  • Title: Digital System Multimedia Sensor
  • Brief Description: The ’913 patent relates to a digital security camera system capable of generating and transmitting both high-resolution still image signals and full-motion video signals over a network for surveillance purposes.

3. Grounds for Unpatentability

Ground 1: Obviousness over Seeley, Ohki, and Fernandez - Claims 5, 7, 10, and 11 are obvious over Seeley in view of Ohki and Fernandez.

  • Prior Art Relied Upon: Seeley (Patent 6,069,655), Ohki (European Publication # EP 0 920 211 A2), and Fernandez (Patent 6,697,103).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seeley teaches the core digital camera system, including a plurality of image transducers, separate motion video and still frame compressors, multiple multiplexers, and a network gateway for transmitting dual-mode signals. To this base system, Petitioner added Ohki, which was cited for its teaching of a cylindrical housing designed to mount multiple image transducers in an angularly spaced, radially outward manner to achieve a panoramic view. Finally, Petitioner argued Fernandez provides the limitations of the challenged dependent claims by disclosing various event detectors (e.g., a smoke detector, manually operated switches, alarm trigger switches) and wireless communication capabilities, including a remote device with a wireless transmitter for generating an activation signal.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Seeley's camera system with Ohki's housing to achieve a panoramic surveillance view, a known and desirable goal in security systems. A POSITA would be further motivated to add the various common sensors and wireless triggers taught by Fernandez to this combined system to enhance its functionality and versatility. Petitioner asserted this combination involves using known components for their intended purposes to yield a predictable result.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involves the straightforward integration of well-known components (cameras, housings, sensors) common in surveillance and security systems.

Ground 2: Obviousness over Brusewitz and Ohki - Claims 1-6, 8-10, 13, 17, and 19 are obvious over Brusewitz in view of Ohki.

  • Prior Art Relied Upon: Brusewitz (Patent 6,038,257) and Ohki (European Publication # EP 0 920 211 A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Brusewitz serves as an alternative primary reference to Seeley, disclosing a digital imaging system that creates and transmits both high-resolution still images and lower-resolution video images. Brusewitz teaches interleaving these two data streams, using an encoder for compression, and enabling network connectivity through a GSM module. As in the first ground, Ohki provides the teaching of a cylindrical housing for arranging multiple Brusewitz-type camera transducers to achieve a complete, panoramic view of a surveillance area. The combination allegedly meets all limitations of the independent claims.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to mount multiple camera sensors of the type taught by Brusewitz within a housing arrangement as taught by Ohki. This combination was framed as a routine substitution of multiple cameras for a single camera to achieve the common and predictable goal of providing a wider, panoramic view of an area for enhanced surveillance.
    • Expectation of Success: A POSITA would expect the combination to be successful, as it entails the simple substitution of known elements for their established functions to achieve a predictable improvement in the field of view.

Ground 3: Obviousness over Umeda and Ohki - Claims 1-6, 9-10, 17, and 19 are obvious over Umeda in view of Ohki.

  • Prior Art Relied Upon: Umeda (Patent 6,452,632) and Ohki (European Publication # EP 0 920 211 A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Umeda as a third primary reference disclosing a complete image sensor and video system. Umeda explicitly teaches the use of standard compression technologies like JPEG for still images and various MPEG standards for motion video. Its architecture includes distinct motion video and still video signal processors, a switch circuit acting as a first multiplexer, and a system multiplexing encoder for network transmission. Again, Ohki was combined to supply the cylindrical, panoramic camera housing to arrange multiple Umeda-type image sensors to provide a complete view of a monitored area.
    • Motivation to Combine: The motivation was consistent with the other grounds: to combine a known, full-featured camera system (Umeda) with a known multi-camera housing (Ohki) to create a panoramic surveillance system. Petitioner contended this would have been an obvious design choice for a POSITA seeking to expand the coverage area of a security camera in a predictable manner.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the Umeda sensor system with the Ohki housing, as both components were well-understood in the art and their combination was for their intended, conventional purposes.
  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, including grounds based on Seeley alone; grounds combining Seeley, Brusewitz, or Umeda with Ohki and further in view of Sorokin (for planar housing arrays); and grounds combining the primary references with Ohki and Fernandez for different claim sets.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-11, 13, 14, 17, 19, and 31-33 of the ’913 patent as unpatentable.