PTAB

IPR2014-00934

HTC Corp v. Flashpoint Technology Inc

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1. Case Identification

2. Patent Overview

  • Title: Creating a Slide Show with Real-Time Audio in a Digital Camera
  • Brief Description: The ’736 patent discloses methods and apparatuses for creating a multimedia presentation in a digital camera. The core technology involves continuously recording an audio track while capturing multiple, high-resolution still images at specific times along the audio timeline, enabling synchronized playback as a "slide show."

3. Grounds for Unpatentability

Ground 1: Obviousness over Kerns and Kuba - Claims 1-14 are obvious over Kerns in view of Kuba.

  • Prior Art Relied Upon: Kerns (Patent 5,367,332) and Kuba (Patent 5,806,072).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kerns disclosed the foundational digital camera system capable of continuously and simultaneously capturing images and sound to record an event, storing them in memory (ring buffers), and allowing an operator to review the recorded event. However, Kerns lacked specific details on file formats for synchronized playback. Petitioner asserted that Kuba remedied this by teaching a digital camera that stores sound and images with capture-time information in a specific file format, enabling a time-sequential playback mode where images are displayed based on their capture times relative to a continuous audio track.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Kuba's file format and time-sequential playback method with Kerns' camera system. The motivation was to implement Kerns' stated goal of capturing and reviewing an event in a more efficient and organized manner, as Kuba’s techniques for retrieving and reproducing sound and images based on time data were a known and logical solution for managing such multimedia content.
    • Expectation of Success: A POSITA would have a high expectation of success, as both references operated in the same technical field of digital cameras with simultaneous audio/image recording and playback, and the combination represented the integration of a known data management technique (Kuba) into a compatible system (Kerns).

Ground 2: Obviousness over Van Luyt and Kerns - Claims 1-14 are obvious over Van Luyt in view of Kerns.

  • Prior Art Relied Upon: Van Luyt (Patent 4,794,465) and Kerns (Patent 5,367,332).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Van Luyt taught a method of creating and playing back a "slide show" by recording multiple pictures and a corresponding audio signal onto a record carrier (e.g., a compact disc). Van Luyt explicitly disclosed embedding time information to allow for synchronized reproduction of the images and audio. Petitioner argued that Kerns complemented this by disclosing a digital camera with user-operable controls (e.g., start/stop buttons) for capturing events and the capability of storing data on a compact disc.
    • Motivation to Combine: The primary motivation was to improve the functionality of Van Luyt’s system. A POSITA would incorporate the user-friendly start-and-stop button controls from Kerns to provide direct user control over the recording process taught by Van Luyt. Furthermore, since Van Luyt’s CD-I format was a known standard, it would have been obvious to implement its recording and playback method within the digital camera architecture described by Kerns.
    • Expectation of Success: Success was predictable because combining a known user interface control (button from Kerns) with a multimedia recording system (Van Luyt) was a routine design choice. Both references provided detailed technical guidance, making their integration straightforward for a POSITA.

Ground 3: Obviousness over Fukuoka, Ota, and Takahashi - Claims 1-4, 7-10, 13, and 14 are obvious over Fukuoka in view of Ota and Takahashi.

  • Prior Art Relied Upon: Fukuoka (Patent 5,614,946), Ota (Patent 5,032,918), and Takahashi (Japanese Published Appl. No. H06-197307).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fukuoka disclosed a still camera that met the core claim elements by simultaneously and continuously recording synchronized images and audio to a memory card. Fukuoka’s system created a time-based timeline by capturing images at a fixed rate (e.g., 60 fields per second) and storing corresponding audio in the image file header. Ota was cited for teaching a similar camera with explicit user control buttons for starting and stopping recording. Takahashi was introduced for its teaching of using an industry-standard SMPTE time code to maintain precise synchronization between audio and images.
    • Motivation to Combine: A POSITA would combine these references to create an improved, more robust, and user-friendly product. The motivation to add Ota’s control buttons to Fukuoka’s camera was to provide better usability. The motivation to incorporate Takahashi’s SMPTE time code was to benefit from a well-established industry standard that would improve interoperability and ensure more reliable synchronization than Fukuoka’s inherent timing method.
    • Expectation of Success: The combination was a predictable integration of known, complementary features. Combining specific control buttons and standard time codes with a base camera system were common engineering practices with a high likelihood of success.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 5, 6, 11, and 12 based on the combination of Fukuoka, Ota, and Takahashi in view of Blazek (Patent 4,791,477), which was cited for its disclosure of a hand-held camera with buttons to start and stop audio recording.

4. Key Claim Construction Positions

  • Petitioner argued that several means-plus-function terms in claim 7 lacked corresponding structure in the ’736 patent’s specification and should be construed broadly under the broadest reasonable interpretation (BRI) standard.
    • "Means for continuously recording audio and storing the audio in the memory": Petitioner proposed this be construed as "a digital camera capable of recording and storing audio," asserting the patent failed to disclose any specific structure, such as a microphone or a specific algorithm, for performing the function.
    • "Means for capturing a plurality of still images": Petitioner proposed this be construed as "an imaging device that captures still images," arguing the specification identified the imaging device and computer as the relevant structures.
    • "Means for presenting a slide show...": Petitioner proposed this be construed as "a display for displaying images and a sound producing device for playing audio," arguing the patent disclosed a viewfinder or display panel but failed to disclose any structure for producing sound, such as a speaker.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-14 of the ’736 patent as unpatentable under 35 U.S.C. §103.