PTAB

IPR2016-00212

Google Inc v. Vedanti Systems Ltd

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: System and Method for Transmitting Data
  • Brief Description: The ’339 patent describes systems and methods for data optimization to reduce the amount of data needed for transmission, particularly for images. The technology involves analyzing an image frame, dividing it into regions (matrices) of varying sizes based on the level of detail, and transmitting only a selection of pixels from those regions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Spriggs in view of Golin - Claims 1, 6, 7, 9, 10, 12, and 13 are obvious over Spriggs in view of Golin under 35 U.S.C. §103.

  • Prior Art Relied Upon: Spriggs (Patent 4,791,486) and Golin (Patent 5,225,904).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Spriggs taught a method and apparatus for image data transmission that reduces the amount of data needed. Spriggs achieved this by recursively subdividing a picture area into blocks of varying sizes, with more subdivisions (smaller blocks) in areas of "fine detail." Spriggs then transmitted only the corner pixel values for each block, allowing a receiver to reconstruct the image via interpolation. Petitioner contended this disclosed the core limitations of the ’339 patent, including analyzing a frame, generating region data based on detail level, selecting pixel data for transmission, and a receiving system to generate a display.

      However, Spriggs determined the level of detail by comparing the actual block to a hypothetical block interpolated from corner values. Petitioner asserted that Golin taught an alternative, well-known technique for this exact purpose. Golin described a "quad-tree decomposition" method where blocks are subdivided based on a "roughness test" that detects edges by comparing adjacent pixels and checking if their difference exceeds a threshold. The combination of Spriggs and Golin, therefore, rendered the challenged claims obvious. The combination supplied the specific limitation of using pixel variation (e.g., adjacent pixel comparison) to determine region size, as recited in the ’339 patent claims.

    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to combine the references as a simple substitution of one known element for another to achieve a predictable result. Both Spriggs and Golin addressed the same problem of how to efficiently subdivide an image for data reduction based on pixel variation. A POSITA would have recognized Spriggs's interpolation method and Golin's adjacent-pixel "roughness test" as interchangeable design choices for determining block complexity. Golin itself suggested that other regionalization strategies were possible, pointing toward the interchangeability of such techniques.

    • Expectation of Success: A POSITA would have had a reasonable expectation of success in substituting Golin’s edge detection method into Spriggs’s framework. The substitution would predictably result in a system that makes block subdivision decisions based on adjacent pixel variation according to a predetermined tolerance, which is precisely the functionality described in the ’339 patent.

4. Key Claim Construction Positions

  • Petitioner asserted that, for the purposes of the IPR, several key terms required construction based on the specification and prosecution history.
  • "pixel selection data" / "selection pixel data": This term was central to Petitioner's argument. Petitioner argued it should be construed as "selected pixel data transmitted without any further processing for each region in a frame." This construction was based on repeated statements made by the patent applicants during prosecution to distinguish their invention from prior art compression techniques. Applicants had emphasized that their invention was for "data optimization instead of data compression" and that the generated pixel data was "selected directly" and transmitted "without any further processing." Petitioner argued this characterization should be given weight by the Board.
  • "high detail" / "low detail": Petitioner proposed construing "high detail" as the "amount of variation between pixels exceeds a predetermined tolerance" and "low detail" as when the variation does not. This construction was based on the specification’s description of a "pixel variation system" that compares adjacent pixels against a tolerance to determine the level of detail.
  • "analysis system": Petitioner argued that "analysis system" in claim 1 should be construed as "frame analysis system" to provide antecedent basis for dependent claims and for consistency with the specification's description of "frame analysis system 106."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 6, 7, 9, 10, 12, and 13 of the ’339 patent as unpatentable.