Google Inc v. Grandeye Ltd

1. Case Identification

• Case #: IPR2013-00548
• Patent #: 7,542,035
• Filed: August 30, 2013
• Petitioner(s): Google Inc.
• Patent Owner(s): Grandeye Ltd.
• Challenged Claims: 1, 7, 13, 22, 33, 44, 53, 54, 69, 73, 78, 80, 82-84, 86, 89, 98, 102, 105, 113, 115, 118-121, and 123

2. Patent Overview

• Title: Method for representing a three-dimensional world on a two-dimensional display
• Brief Description: The ’035 patent discloses methods for displaying full-surround image data. The core steps involve providing the full-surround data, texture mapping it onto a three-dimensional surface representation ("p-surface"), allowing a user to select a viewpoint and direction, and displaying the selected portion of the texture-mapped surface.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1, 22, 53, 54, and others 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," a 1996 publication).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Photo VR discloses an image-based virtual reality viewing system that meets every limitation of the independent claims. Photo VR teaches capturing the "whole view" of a scene from a camera position (full-surround image data), texture mapping this data onto a "sphere-like polyhedron" (a p-surface comprised of polygons approximating a sphere), allowing a user to select a viewpoint and zoom level via a mouse or keyboard, and displaying the selected portion of the polyhedron in an "object viewer" on a computer screen.

Ground 2: Obviousness over QuickTime VR and Photo VR - Claims 1, 22, 53, 54, and others 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," a 1995 publication) and Photo VR.
• Core Argument for this Ground:
  • Prior Art Mapping: QuickTime VR disclosed an interactive system for viewing panoramic images texture-mapped onto a cylinder. Petitioner contended this system taught most claim limitations but noted its cylindrical map created a limited vertical viewing angle, as it could not cover the top and bottom views. Photo VR expressly identified this "common problem" with cylindrical environment maps and proposed a solution: using sphere-like polyhedral environment maps to provide complete coverage.
  • Motivation to Combine: A POSITA would combine these references because Photo VR is explicitly presented as an improvement upon the technology of QuickTime VR. It directly addresses a known deficiency (limited vertical view) in systems like QuickTime VR with a specific, disclosed solution (using a spherical p-surface instead of a cylindrical one).
  • Expectation of Success: A POSITA would have had a high expectation of success in applying the teachings of Photo VR to a system like QuickTime VR to achieve the predictable result of a full-surround view, as this was the stated purpose of the Photo VR method.

Ground 3: Obviousness over Miller, Haeberli, and Gullichsen - Claims 1, 7, 13, 22, 33, 44, and others are obvious over Miller in view of Haeberli and Gullichsen

• Prior Art Relied Upon: Miller (Patent 5,446,833), Haeberli ("Texture Mapping as a Fundamental Drawing Primitive," a 1993 publication), and Gullichsen (Patent 5,796,426).

• Core Argument for this Ground:

  • Prior Art Mapping: Miller disclosed a method for rendering textured spheres and spherical environment maps, recognizing the prior art's shortcoming in not capturing a scene in every direction and teaching a system that "samples the environment completely." Haeberli provided foundational techniques for texture mapping onto various surfaces, including cubes and spheres. Gullichsen taught an apparatus for capturing full-surround image data using wide-angle or fisheye lenses and algorithms to de-warp the captured images for display.
  • Motivation to Combine: A POSITA would combine these references as they all pertain to the analogous arts of image processing and computer graphics. Miller taught a system for rendering full-surround data and explicitly suggested incorporating other "known texture maps." Haeberli provided well-known, flexible texture mapping methods that a POSITA could substitute into Miller's system. Gullichsen provided a superior method for capturing the very data used by systems like Miller, making it an obvious component to integrate for improved results.

• Additional Grounds: Petitioner asserted numerous additional anticipation and obviousness challenges, including grounds based on Lipscomb (Patent 6,031,541) and Luken (Patent 5,923,334), which similarly relied on combining known methods for capturing, texture mapping, and displaying panoramic or full-surround image data.

4. Key Claim Construction Positions

• Full-Surround (Image) Data: Petitioner argued for a broad construction based on the specification's definition as "data which samples the points P." Petitioner asserted that under this Broadest Reasonable Interpretation (BRI), the term covers prior art examples that "sample the environment completely" or capture the "whole view" of a room.
• P-Surface: Based on the specification's complex definition of a surface with a well-defined inside and outside, Petitioner proposed that the BRI encompasses prior art shapes such as a "sphere-like polyhedron," "sphere," "cube," and "polyhedral environment map."
• Texture Mapping: As the specification did not narrowly define this term and referred to standard techniques, Petitioner proposed a BRI of "to apply color data to a virtual shape or polygon." This construction was intended to include known prior art techniques like environment mapping.

5. Key Technical Contentions (Beyond Claim Construction)

• Petitioner's central technical contention was that the ’035 patent did not invent the underlying technology but merely recast well-known prior art concepts using new, self-defined terminology. Petitioner argued that terms presented as novel, such as "p-surface" and "full-surround image data," were simply the patentee's labels for concepts like rendered spheres, polyhedra, and complete image data that were already ubiquitous in the prior art of computer graphics and image processing.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1, 7, 13, 22, 33, 44, 53, 54, 69, 73, 78, 80, 82-84, 86, 89, 98, 102, 105, 113, 115, 118-121, and 123 of the ’035 patent as unpatentable under 35 U.S.C. §§ 102 and 103.