PTAB

IPR2016-01203

Apple Inc v. FastVDO LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus of Encoding Data
  • Brief Description: The ’482 patent discloses an error-resilient data encoding method using "split-field coding." The technique generates code words with a first portion (prefix) and a second portion (suffix), where the prefix contains information about the suffix (e.g., its length) and is provided with a higher level of error protection to prevent error propagation during transmission or storage.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kato - Claims 1-3, 5-14, 16-17, 22-26, and 28-29 are obvious over Kato

  • Prior Art Relied Upon: Kato (Patent 5,392,037).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kato teaches an error-resilient encoding method that anticipates nearly every element of the challenged claims. Kato discloses a split-field coding scheme where input data is encoded into code words (Ci) having a first portion (Pi) and a second portion (Ri). The first portion contains information representative of the code word’s total length, which allows a decoder to determine the length of the second portion. Crucially, Kato teaches applying higher error protection to the first portions than the second portions by storing them in separate, differently protected "data store regions," for the express purpose of preventing error propagation—the same problem addressed by the ’482 patent. Petitioner contended that Kato also discloses applying this method to data that has undergone transformation and quantization, meeting limitations in dependent claims.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, Petitioner's argument centered on obvious modifications. Petitioner argued that to the extent Kato’s first portion (Pi) represents the total code word length (L1+L2) rather than just the second portion's length (L2), it would have been an obvious substitution for a POSITA. Modifying the prefix to contain L2 directly instead of L1+L2 was presented as a simple design choice from a finite number of predictable solutions, providing the same information to the decoder with a reasonable expectation of success.
    • Key Aspects: The core of the argument was that Kato teaches the same fundamental structure (split-field code), for the same purpose (error resilience), using the same technique (unequal error protection on the prefix).

Ground 2: Obviousness over Fiala, Fazel, and Fazel ’622 - Claims 1-3, 5-14, 16-17, 22-26, and 28-29 are obvious over Fiala in view of Fazel and Fazel ’622

  • Prior Art Relied Upon: Fiala (a 1989 ACM article admitted as prior art in the ’482 patent), Fazel (a 1990 IEEE article), and Fazel ’622 (Patent 5,218,622).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Fiala, as admitted prior art, discloses the foundational split-field coding method where a prefix (e.g., a unary code) specifies the length of the following suffix field. However, Fiala does not explicitly discuss its use in noisy channels or the application of error protection. The Fazel references were argued to remedy this by teaching the principle of unequal error protection (UEP) for encoded data. Specifically, Fazel teaches that for robust transmission, the most important information, such as frame length data needed for synchronization, must be "protected very efficiently." Fazel ’622 further discloses a system for variable-length coding that incorporates selective, unequal error protection.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Fiala's split-field coding with the UEP taught by Fazel and Fazel ’622 to ensure robust data transmission over noisy channels. The motivation was to apply a well-known error correction technique (UEP) to a known data structure (Fiala's prefix/suffix code) to solve the known problem of data corruption during transmission. A POSITA would have recognized that the prefix in Fiala, which contains critical length information, is analogous to the "most important information" described in Fazel and would have been motivated to provide it with a higher degree of error protection.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success, as this combination involved applying a known technique to a known system to achieve a predictable and desired result: improved error resilience.

4. Key Claim Construction Positions

Petitioner argued that numerous means-plus-function limitations are indefinite under §112 for failure to disclose corresponding structure or algorithms in the specification.

  • "Error protection means" (Claims 7, 22): Petitioner contended this term is indefinite because the specification fails to disclose any specific structure or algorithm for performing unequal error protection. The patent’s only disclosure is a generic reference to techniques "known to those skilled in the art" and the title of a 600-page textbook, which was argued to be insufficient to provide the required corresponding structure.
  • "Code word generating means," "first generating means," "second generating means" (Claims 7, 22, 24): Petitioner argued these nested means-plus-function terms are indefinite. The specification suggests implementation via a computer or controller but fails to disclose the specific algorithms for performing the claimed functions (e.g., generating a prefix using unary coding or a suffix using binary coding).
  • "Entropy coding means" (Claims 8, 23): This term was argued to be indefinite because the specification identifies entropy coding only as a functional block in a figure and fails to disclose a specific algorithm, such as Huffman or Arithmetic coding, to perform the function.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-3, 5-14, 16-17, 22-26, and 28-29 of the ’482 patent as unpatentable.