PTAB

IPR2013-00547

Google Inc v. Grandeye Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Modeling of the Visible World
  • Brief Description: The ’099 patent describes a method for representing the three-dimensional visible world on a two-dimensional display. The method involves providing "full-surround image data," selecting a viewpoint, texture mapping the image data onto a three-dimensional surface ("p-surface"), and displaying a selected portion of the resulting texture-mapped surface.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1, 3-5, 11, and 13 are anticipated by Photo VR

  • Prior Art Relied Upon: Photo VR ("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, an image-based virtual reality viewing system, disclosed every limitation of the challenged claims. Photo VR taught capturing the "whole view" from a camera position (disclosing full-surround image data), using a keyboard or mouse to change viewpoint and zoom (disclosing selecting a viewpoint), mapping the image data onto a "sphere-like polyhedron" (disclosing texture mapping onto a p-surface), and showing the result in an "object viewer" on a computer screen (disclosing displaying).
    • Key Aspects: Petitioner contended that Photo VR explicitly integrated image processing and computer graphics concepts to allow interactive navigation of panoramic images, directly corresponding to the method claimed in the ’099 patent.

Ground 2: Obviousness - Claims 1, 3-5, 11, and 13 are obvious over Miller in view of Haeberli

  • 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 alone anticipated the claims by disclosing a method for rendering textured spheres and spherical environment maps. Miller taught using image data that "samples the environment completely" (full-surround image data) and mapping it onto "a sphere in 3-D space" (a p-surface). A user could "interact with the textured spheres... in real-time" to control the view direction. Haeberli was cited as further teaching standard texture mapping techniques onto various surfaces, including cubes and spheres, which were well-known at the time.
    • Motivation to Combine: A POSITA would combine these references to apply a known, fundamental technique (texture mapping from Haeberli) to a known method of displaying panoramic images (Miller) to achieve predictable results. Miller itself stated that rendering spherical maps could be done using "a number of different known approaches," motivating a POSITA to look to foundational texts like Haeberli for such techniques.
    • Expectation of Success: Combining Haeberli's fundamental texture mapping with Miller's environment mapping system was a simple substitution of one known technique for another, and a POSITA would have had a high expectation of success in producing an interactive, panoramic viewer.

Ground 3: Obviousness - Claims 1, 3-5, 11, and 13 are obvious over QuickTime VR in view of Photo VR

  • Prior Art Relied Upon: QuickTime VR ("QuickTime VR – An Image-Based Approach to Virtual Environment Navigation," published 1995) and Photo VR.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that QuickTime VR taught an image-based virtual reality system that texture-mapped images onto a cylindrical environment map, allowing a user to pan, zoom, and navigate a scene. However, QuickTime VR acknowledged its own limitation in not being able to look straight up or down due to its use of a cylindrical map. Photo VR explicitly identified and solved this exact problem by proposing the use of "sphere-like polyhedral environment maps" to provide a full field of view.
    • Motivation to Combine: The motivation was exceptionally strong and explicit. Photo VR was presented as a direct improvement to overcome the specific, known deficiencies of systems like QuickTime VR. A POSITA seeking to improve the limited vertical viewing angle of QuickTime VR would have been directly motivated to adopt the solution proposed in Photo VR: replacing the cylindrical map with a spherical or polyhedral one.
    • Expectation of Success: Because Photo VR provided a specific solution to a known problem in the prior art, a POSITA would have had a very high expectation of success in combining the teachings to create a fully immersive panoramic viewer.

  • Additional Grounds: Petitioner asserted seven additional anticipation and obviousness challenges. These grounds relied on similar theories but used different primary references, including Lipscomb (Patent 6,031,541), Gullichsen (Patent 5,796,426), and Luken (Patent 5,923,334), either alone or in combination with Haeberli or Lipscomb.

4. Key Claim Construction Positions

  • Full-Surround (Image) Data: Petitioner argued this term should be construed broadly under the Broadest Reasonable Interpretation (BRI) standard to include prior art concepts like "sampling the environment completely" or capturing the "whole view" from a camera.
  • P-Surface / P-Sphere: Petitioner asserted these terms, defined in the specification to include shapes like spheres, cubes, and polyhedra, should encompass prior art disclosures of "sphere-like polyhedrons," "polyhedral environment maps," and "textured spheres."
  • Texture Mapping: As the specification did not narrowly define this term and referred to standard computer graphics systems, Petitioner argued it should be construed broadly to include known techniques for both texture mapping and environment mapping disclosed in the prior art.

5. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner's central technical contention was that the ’099 patent did not invent new technology but merely recast well-known, conventional prior art concepts using new, self-defined terminology. It argued that terms like "full-surround image data" and "p-surface" were simply new names for established concepts like panoramic images and 3D geometric primitives, which were widely known and used in the art before the patent's priority date.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 3-5, 11, and 13 of the ’099 patent as unpatentable.