Avigilon USA Corp Inc v. JDS Technologies Inc

1. Case Identification

• Case #: IPR2016-00532
• Patent #: 6,891,566
• Filed: January 29, 2016
• Petitioner(s): Avigilon USA Corporation, Inc. and Avigilon Corporation
• Patent Owner(s): JDS Technologies, Inc.
• Challenged Claims: 29-46

2. Patent Overview

• Title: Digital Video System and Method
• Brief Description: The ’566 patent discloses a digital video system, such as a surveillance system, where a computer connects to multiple cameras over a network. The system includes a user interface for viewing camera feeds and is capable of detecting motion by comparing color component values for pixels from different video images.

3. Grounds for Unpatentability

Ground 1: Claims 29-30 are obvious over AXIS Publications and admitted prior art.

• Prior Art Relied Upon: AXIS Publications (consisting of the AXIS 240 user manual (publicly available May 7, 1999) and Flightcam Publications (publicly available Nov. 28, 1999)) and Applicant's admitted prior art.
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the AXIS Publications teach a computer readable medium (e.g., a hard drive storing a web browser) for providing an interface to multiple cameras over a network, as recited in the preamble of claim 29. The AXIS 240 video server connects cameras to a network, and a user's computer with a web browser accesses the server, thereby providing an interface. The AXIS manual allegedly taught monitoring the network for a "trigger event" via a "CRON script" that could send a message to a remote host upon an event, such as an input port going high. The ’566 patent itself admitted that using a CRON script for triggering was known art.
  • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSA) would combine the teachings of the AXIS manual with the user interface display shown in the Flightcam Publications, which was an exemplary use case for the same AXIS 240 server. The motivation was to provide a more convenient, user-friendly display showing all cameras simultaneously rather than requiring access to a separate interface for each camera.
  • Expectation of Success: Success was expected because the combination merely involved applying a known user interface layout (from Flightcam) to the established functionality of the AXIS 240 server system, which was the core technology in both references.

Ground 2: Claim 31 is obvious over AXIS Publications and Winter.

• Prior Art Relied Upon: AXIS Publications and Winter (WO 1998/019450).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground incorporated the arguments for claims 29-30 and added Winter to teach the final limitation of claim 31: a program operable to initiate recording of images in response to a user selection. Petitioner asserted that Winter, which discloses a closed-circuit video surveillance system, teaches a user interface form that permits a user to schedule recording modes for a plurality of cameras. This allegedly corresponds to the claimed "form that permits the user to initiate recording."
  • Motivation to Combine: A POSA would combine Winter with the AXIS system to add a necessary feature. Since the AXIS system allowed simultaneous viewing of multiple cameras and surveillance video creates large data volumes, a POSA would have sought a way to selectively record specific cameras at specific times to save storage space. Winter provided a known method for implementing such a user-controlled recording interface.
  • Expectation of Success: The combination was a predictable integration of a known user interface feature (user-initiated recording from Winter) into a standard network video system (AXIS), using conventional programming techniques to achieve the expected result of improved data management.

Ground 3: Claim 32 is anticipated by Hanko.

• Prior Art Relied Upon: Hanko (Patent 6,493,041).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Hanko, which discloses a method for motion detection in video, anticipates every element of claim 32. Hanko teaches a computer readable medium with a program for detecting motion in color video images. The program compares pixels of an incoming frame to a reference frame. Hanko explicitly defines a pixel's "value" to include one or more color component values (e.g., in a YUV scheme). Petitioner argued that Hanko's teaching to "operate on the full color value of each pixel" inherently teaches maintaining a separate counter for each color component, as this is a direct implementation of that teaching. Hanko's system then generates a motion detect signal based on the counts stored in the counters exceeding a threshold.

• Additional Grounds: Petitioner asserted additional challenges, primarily that claims 33-46 are obvious over Hanko in various combinations with Winter and Applicant's admitted prior art. These grounds argued that adding features like user-selectable thresholds (from Winter), real-time processing (inherent in Winter), region-of-interest masking (from Winter), and use of RGB color values (admitted by Applicant during prosecution) were all obvious modifications to Hanko's core motion detection system to improve performance, usability, and data management.

4. Key Claim Construction Positions

• "Color component" (claims 32, 33, 45): Petitioner proposed this term means one of the plurality of numbers used to represent color information for a pixel in an image (e.g., the red, green, or blue value in an RGB color space). This construction was based on the specification and was central to the argument that Hanko's disclosure of operating on the "full color value" of a pixel inherently taught processing individual color components.
• "Trigger event" (claims 29, 30): Proposed to mean an event that initiates an action, such as broadcasting a message upon detecting a sensor input. This construction, based on the ’566 patent's examples, was used to argue that the "CRON script" functionality in the AXIS manual met this limitation.
• "Create the mask by erasing" (claim 39): Petitioner argued this means creating the mask using any image editing tool. As "erase" does not appear in the specification outside the claim, Petitioner looked to the specification's description of using Microsoft Paint or another image editor to "refine the mask to the pixel level" to support a broad construction that was met by Winter's interface for defining a region of interest.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 29-46 of the ’566 patent as unpatentable.