Mobotix Corp v. E Watch Corp

1. Case Identification

• Case #: IPR2013-00498
• Patent #: 7,023,913
• Filed: August 7, 2013
• Petitioner(s): Mobotix Corporation
• Patent Owner(s): Monroe
• Challenged Claims: 12, 15, 16, 18, 20-30, and 34-37

2. Patent Overview

• Title: Digital System Multimedia Sensor
• Brief Description: The ’913 patent discloses a fully digital camera system capable of providing high-resolution still images and streaming video signals over a network to a centralized, server-supported security and surveillance system. The system uses multiple image transducers and separate compressors for still and motion video.

3. Grounds for Unpatentability

Ground 1: Obviousness over Seeley and Ohki - Claims 21-30 are obvious over Seeley in view of Ohki.

• Prior Art Relied Upon: Seeley (Patent 6,069,655) and Ohki (European Patent Application EP 0 920 211 A2).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Seeley taught the core digital security camera system of the independent claims, including a plurality of image transducers, separate motion video and still frame compressors, and multiple multiplexers for combining and transmitting the image data over a network. Ohki was alleged to teach the specific housing limitations, disclosing various mounting arrangements for multiple surveillance cameras, including a cylindrical housing where transducers are angularly spaced and aimed radially outward to create a panoramic view, as recited in independent claim 21. Dependent claims related to power supplies, data storage, and mounting features were argued to be obvious additions of well-known components.
  • Motivation to Combine: A POSITA would combine the camera system of Seeley with the multi-camera housing of Ohki to achieve the predictable result of a panoramic surveillance system. This combination was presented as a routine substitution of multiple camera sensors into a specialized housing to provide a complete view of an area.
  • Expectation of Success: The combination involved applying known technologies (multi-camera housings) to a known type of system (digital surveillance cameras) to achieve a predictable improvement in the field of view, ensuring an expectation of success.

Ground 2: Obviousness over Brusewitz and Ohki - Claims 12, 18, and 21-30 are obvious over Brusewitz in view of Ohki.

• Prior Art Relied Upon: Brusewitz (WO 1998041022) and Ohki (European Patent Application EP 0 920 211 A2).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner presented Brusewitz as an alternative primary reference to Seeley. Brusewitz was argued to teach a digital camera imaging system that captures and transmits both high-resolution still images and motion video, expressly disclosing the interleaving of these two data streams, which satisfies the claim requirement for a first multiplexer. As in the previous ground, Ohki was relied upon to teach the cylindrical housing with an array of radially aimed transducers. The combination of Brusewitz's camera internals with Ohki's housing was alleged to render the independent and dependent claims obvious.
  • Motivation to Combine: A POSITA would be motivated to mount multiple cameras of the type taught by Brusewitz in an arrangement taught by Ohki. This was supported by Brusewitz’s own disclosure that its camera is suitable for surveillance systems, making its integration into a multi-camera housing a logical and foreseeable design choice to expand the viewing area.
  • Expectation of Success: Success was expected because the combination merely involved placing a known type of camera (Brusewitz) into a known type of multi-camera housing (Ohki) to achieve the known benefit of panoramic surveillance.

Ground 3: Obviousness over Umeda, Ohki, and Neta - Claims 15 and 34 are obvious over Umeda in view of Ohki and further in view of Neta.

• Prior Art Relied Upon: Umeda (Japanese Patent Application No. H10-224696), Ohki (European Patent Application EP 0 920 211 A2), and Neta (Patent 5,200,818).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground challenged claims requiring a spherical housing. Petitioner argued Umeda taught a camera system with still and motion video compression and network transmission, similar to Seeley and Brusewitz. Neta was introduced to teach multi-camera surveillance systems mounted in various housings, including hemispherical arrangements, and explicitly noted that "the basic shape of the field of view is spherical." Ohki's teachings on multi-camera housings were used to support the general concept. The combination allegedly taught all elements of claims 15 and 34, which recite a spherical housing for providing coverage of a three-dimensional space.
  • Motivation to Combine: A POSITA would combine the camera sensors of Umeda and the multi-camera housing concepts from Ohki with the spherical housing taught by Neta to capture a wide, spherical field of view. This combination was framed as a substitution of known components to achieve the predictable result of full three-dimensional image collection, as suggested by Neta.
  • Expectation of Success: A POSITA would have a high expectation of success in creating a spherical surveillance camera, as Neta explicitly taught using such a shape to match a spherical field of view.

• Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations of these core references. These included challenges using Seeley, Brusewitz, or Umeda as the primary system reference, combined with Ohki and/or Neta to teach various housing configurations, such as an "axial sliced cylinder" housing for flat-surface mounting.

4. Key Claim Construction Positions

• "multiplexer": Petitioner proposed the construction "a device for combining two or more input signals into at least one output signal," arguing this represents the term's plain and ordinary meaning. This construction was important for identifying multiplexing functions in the prior art, such as the interleaving taught by Brusewitz.
• "wherein the full motion video compressor is a JPEG chip" (Claim 18): Petitioner argued this phrase should be construed broadly to include a chip using the M-JPEG (Motion-JPEG) compression technique. This was based on the specification's incorporation by reference of another patent that described M-JPEG as a motion video compression method.
• "means for supporting..." (Claim 28): Petitioner identified this as a means-plus-function limitation under 35 U.S.C. §112, para. 6. The function was identified as "supporting the camera from the ceiling," and the corresponding structure disclosed in the specification was identified as the "ceiling post" shown in Figure 21C of the ’913 patent.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 12, 15, 16, 18, 20-30, and 34-37 of the ’913 patent as unpatentable.