PTAB

IPR2017-00099

SamSung ElecTronics Co Ltd v. InfobRidge Pte Ltd

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1. Case Identification

  • Patent #: 8,917,772
  • Filed: October 17, 2016
  • Petitioner(s): Samsung Electronics Co., Ltd.
  • Patent Owner(s): Infobridge Pte. Ltd.
  • Challenged Claims: 1-7

2. Patent Overview

  • Title: Method for Constructing a Merge Candidate List in Video Coding
  • Brief Description: The ’772 patent relates to a method for constructing a merge candidate list for a current block during video encoding or decoding in "merge mode." The technology is designed to improve video compression efficiency by deriving motion information for a current block from neighboring spatial and temporal blocks, thereby reducing the amount of data that needs to be explicitly transmitted.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-7 over WD4

  • Prior Art Relied Upon: WD4 (JCTVC-F803, Working Draft 4 of High-Efficiency Video Coding, Oct. 2011).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that WD4, a working draft of the HEVC standard, discloses every limitation of claims 1-7. For independent claim 1, Petitioner asserted that WD4 teaches a method of constructing a "mergeCandList" by: (a) checking the availability of spatial and temporal merge candidates; (b) constructing the list using the available candidates; and (c) adding additional generated candidates if the number of available candidates is below a predetermined threshold. A central contention for claim 1(h) was that WD4 discloses setting a spatial merge candidate as "unavailable" if the current block is a second prediction unit resulting from an asymmetric partition, and the candidate corresponds to the first prediction unit from that same partition. Petitioner provided detailed mappings for dependent claims 2-7, arguing that specific partition sizes, candidate block relationships, and conditions for disabling asymmetric partitioning were all present in WD4.

Ground 2: Obviousness of Claims 1-7 over WD4 in view of Han

  • Prior Art Relied Upon: WD4 (JCTVC-F803, Working Draft 4 of High-Efficiency Video Coding, Oct. 2011) and Han (Improved Video Compression Efficiency Through Flexible Unit Representation and Corresponding Extension of Coding Tools, IEEE Transactions on Circuits and Systems for Video Technology, Dec. 2010).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1. Petitioner argued that if WD4 were found not to explicitly describe its partition modes (e.g., Part_nLx2N, Part_2NxnU) as "asymmetric," then Han explicitly supplies this missing terminology. Han, a proposal submitted during the HEVC standardization process, discloses the same partition modes and expressly defines them as "asymmetric PU splittings" designed to improve coding efficiency for irregular object boundaries. Petitioner contended that WD4 already disclosed the functional processes associated with these partitions, and Han merely provided the conventional name for them.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Han’s teachings with WD4 because both documents were part of the same HEVC standardization effort, addressed the same technical challenges, and even referenced each other’s proposals. A POSITA would have been motivated to apply the well-understood "asymmetric" label from Han to the corresponding partition modes in WD4 as a matter of common sense to improve coding efficiency, a known goal in the field.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination. The integration involved applying a standard technical definition from Han to the functionally identical processes in WD4, which would have been a predictable and straightforward implementation for anyone working on the HEVC standard.

4. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner dedicated a significant portion of the petition to arguing that the ’772 patent is not entitled to its claimed priority date of November 7, 2011, from a Korean application (’219 KR application). This contention was critical to establishing that both WD4 (Oct. 2011) and Han (Dec. 2010) qualify as prior art under pre-AIA 35 U.S.C. §102.
  • The argument was twofold:
    • Lack of Common Inventorship: Petitioner asserted that the priority claim was procedurally defective because the inventors listed on the ’772 patent (Soo Mi Oh and Moonock Yang) and the inventor of the priority ’219 KR application (Min Jang) were entirely different, with no overlap.
    • Lack of Written Description: Petitioner also contended that the ’219 KR application failed to provide adequate written description support for the subject matter of claims 5 and 6, independently breaking the priority chain for those claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of Patent 8,917,772 as unpatentable.