PTAB

IPR2013-00546

Google Inc v. Grandeye Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Modeling the Visible World
  • Brief Description: The ’176 patent discloses a method for representing a three-dimensional (3D) visible world on a two-dimensional (2D) display. The method involves texture mapping "full-surround image data" onto a virtual 3D surface (termed a "p-surface"), allowing a user to select a viewpoint and direction, and then displaying the selected portion of the model.

3. Grounds for Unpatentability

Ground 1: Anticipation over Photo VR - Claims 1, 4, 12, 16, 17, 19-21 are anticipated under 35 U.S.C. §102 by Photo VR.

  • Prior Art Relied Upon: Photo VR ("A System of Rendering High Quality Images for Virtual Environments Using Sphere-like Polyhedral Environment Maps," published July 30, 1996).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Photo VR, a 1996 publication, discloses every element of the challenged claims. Photo VR describes an image-based virtual reality system for displaying panoramic images on a computer. It teaches capturing the "whole view" of a room (the claimed "full-surround image data") and then "texture mapped" it onto a "sphere-like polyhedr[on]" (the claimed "p-surface" comprising polygons approximating a sphere). The system allows a user to interactively navigate the environment using a keyboard or mouse to select a viewpoint and zoom in on the image, thus allowing a user to select a view and displaying a portion of the model.

Ground 2: Obviousness over Miller and Haeberli - Claims 1, 4, 12, 16, 17, 19-21 are obvious over Miller in view of Haeberli under 35 U.S.C. §103.

  • Prior Art Relied Upon: Miller (Patent 5,446,833) and Haeberli ("Texture Mapping as a Fundamental Drawing Primitive," published June 1993).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Miller, which was cited on the face of the ’176 patent, discloses a method for rendering textured spheres and spherical environment maps. Miller teaches using texture files that "sample[s] the environment completely" (full-surround image data) and renders this data onto "a sphere in 3-D space" (a p-surface). Miller further allows a user to "interact with the textured spheres and environment maps in real-time, with the view direction and field of view under user control." Petitioner argued that Haeberli, a foundational paper on computer graphics, provides further description of well-known texture mapping techniques, including mapping images onto cubes and spheres.
    • Motivation to Combine: A POSITA would combine Miller with Haeberli because Miller itself explicitly teaches incorporating other known texture mapping methods. Haeberli provided a known, flexible, and predictable technique for improving rendered objects. A POSITA would have found it obvious to apply Haeberli's fundamental texture mapping techniques to improve or implement the system disclosed in Miller.
    • Expectation of Success: The combination would have yielded the predictable result of rendering a 3D environment with full-surround image data, as both references operated in the same field of computer graphics and addressed analogous problems.

Ground 3: Obviousness over Gullichsen and Haeberli - Claims 1, 4, 12, 16, 17, 19-21 are obvious over Gullichsen in view of Haeberli under §103.

  • Prior Art Relied Upon: Gullichsen (Patent 5,796,426) and Haeberli.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Gullichsen discloses a viewer for interacting with and displaying a portion of a surface that is texture-mapped with full-surround image data. Gullichsen teaches using cameras with wide-angle fisheye lenses to capture complete environmental data, which is then mapped onto a spherical "non-planar image grid" or the faces of a cube (p-surfaces). A user can select the view direction and zoom via a joystick or head tracking device. Haeberli was again cited for its foundational teachings on the ease of integrating texture mapping onto different p-surfaces like cubes and spheres.
    • Motivation to Combine: A POSITA would have been motivated to combine these references to improve upon existing systems. Gullichsen addresses overcoming distortion in virtual reality systems, and Haeberli describes fundamental, easy-to-integrate texture mapping as a known technique for improving rendered objects. Applying Haeberli's flexible methods to the system in Gullichsen would have been a common-sense approach to achieve improved rendering with predictable results.
    • Expectation of Success: As both references concern displaying 3D environments and using texture mapping, a POSITA would have had a high expectation of success in combining their teachings to create an interactive viewer for full-surround image data.

  • Additional Grounds: Petitioner asserted additional challenges including anticipation by Miller, Lipscomb (Patent 6,031,541), and Gullichsen individually. Further obviousness grounds were asserted based on Lipscomb in view of general POSA knowledge, and Luken (Patent 5,923,334) in view of Haeberli.

4. Key Claim Construction Positions

  • "full-surround image data": Petitioner argued this term should be construed broadly based on the specification's definition as "data which samples the points P... [and] encodes... the association of a color value with a given direction from a given point of projection." Petitioner asserted that prior art examples include "sampl[ing] the environment completely" or capturing a "panoramic scene."
  • "p-surface": Based on the specification's detailed geometric definition and listed examples (cube, sphere, cylinder), Petitioner proposed this term covers any 3D computer graphics representation with a well-defined inside and outside. Prior art examples included a "sphere-like polyhedron," "cube," or "polyhedral environment map."
  • "texture mapping": As the patent does not narrowly define this term and refers to standard graphics systems, Petitioner argued for a broad construction of "to apply color data to a virtual shape or polygon." This construction would encompass known techniques like environment mapping.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4, 12, 16, 17, and 19-21 of Patent 8,077,176 as unpatentable.