PTAB

IPR2016-00522

Avigilon USA Corp Inc v. JDS Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Digital Video System
  • Brief Description: The ’566 patent discloses a computer-readable medium and digital video system for recording a sequence of images. The technology involves storing images from one or more cameras together as a single, concatenated file and using first and second markers to index the file for quick access. The patent also describes a networked digital video system where a client computer accesses images from cameras via one or more video servers.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claim 47 and Obviousness of Claim 48 over Winter

  • Prior Art Relied Upon: Winter (International Publication No. WO1998/019450).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Winter, which discloses a closed-circuit video surveillance system, anticipates every limitation of independent claim 47 and renders the additional limitations of claim 48 obvious. Winter’s system was alleged to store video data in .AVI files, which constitutes storing images together as a single file. Petitioner asserted that Winter’s index data, which provides a “starting date and time and an ending date and time” for each file, corresponds to the claimed first and second markers for identifying the start and end of an image sequence. Furthermore, Winter’s system was argued to automatically index video data periodically as it is stored. For claim 48, Petitioner asserted that Winter’s “video search component” and “archive manager” meet the limitation of an “image viewer program” operable to use the index to locate images.
    • Motivation to Combine (for §103 grounds): The petition argued that the final limitation of claim 48—creating an index if one is not found—was not explicitly taught by Winter but would have been an obvious, common-sense modification. A person of ordinary skill in the art (POSITA) would have been motivated to add this functionality to enable well-known playback features like rewind and fast forward, which rely on indexing.
    • Expectation of Success (for §103 grounds): Success in implementing the index-creation feature would have been expected, as it was a simple, common-sense solution to a known problem in video playback.

Ground 2: Obviousness of Claims 49 and 52-54 over AXIS Manual, Flightcam, and Schell

  • Prior Art Relied Upon: AXIS Manual (a 1999 user manual), Flightcam Publications (a 1999 whitepaper), and Schell (Patent 6,477,648).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that the combination of the AXIS Manual and Flightcam Publications (“AXIS Publications”) discloses the basic digital video system of claim 49. Specifically, these references describe an AXIS 240 camera server that connects multiple cameras to a network, allowing a client computer to access and display images in separate windows. To meet the key limitation of using a “unique number” obtained from the server to “enable or disable the display of images,” Petitioner argued for combining the AXIS system with Schell. Schell was said to teach a security method where a client workstation validates the source address (e.g., a MAC address, which is a unique number) from a server’s data packet against a trusted list before accepting the packet. If the address is not validated, the packet is discarded, effectively disabling data transmission.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Schell’s security method with the AXIS video system to address the known security risks of transmitting potentially confidential information over a network. Petitioner argued the password protection offered by the AXIS system was insufficient against hackers, and a POSITA would have been motivated to supplement it with Schell’s more robust MAC address validation to prevent unauthorized access to the video servers.
    • Expectation of Success (for §103 grounds): Petitioner argued success would be predictable because Schell’s method for authenticating servers was generic and its application to the AXIS system was a routine design choice. Implementing this known technique would predictably yield the benefit of enhanced network security. The dependent claims were met by express disclosures in the AXIS Manual (multi-camera server) and the combination with Schell (validating the unique number).

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 50 and 51. These grounds added Walpole (a 1998 article) to the primary combination to teach the use of a plurality of video servers and AXIS 200 (a 1998 product webpage) to teach a camera server where the video server and camera are integrated into a single unit.

4. Key Claim Construction Positions

  • “Unique number” (claim 49): Petitioner proposed this term means “data that uniquely identifies hardware on a network, such as a MAC address.” This construction was central to the argument that Schell’s disclosure of validating a server’s MAC address met the claim limitation of using a unique number to enable or disable image display.
  • “Digital storage device” (claims 47-48): Proposed as a “device for digitally storing computer code or other data,” including magnetic or optical media.
  • “Program” (claims 47-48): Proposed as “coded software instructions for controlling the operation of a computer or other machine.”

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 47-54 of the ’566 patent as unpatentable.