PTAB

IPR2017-00099

Samsung Electronics Co Ltd v. Infobridge Pte Ltd

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Video Decoding/Encoding Method and Apparatus Using Merge Mode
  • Brief Description: The ’772 patent discloses methods for encoding and decoding video in a "merge mode." The invention focuses on constructing a merge candidate list for a current prediction block by checking the availability of spatial and temporal merge candidates and adding them to the list to derive motion information efficiently.

3. Grounds for Unpatentability

Ground 1: Claims 1-7 are anticipated under 35 U.S.C. §102(b) over WD4.

  • Prior Art Relied Upon: WD4 (JCTVC-F803, version 4, a Working Draft of the High-Efficiency Video Coding standard).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that WD4, a publicly available 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 checking the availability of five spatial merge candidates (A0, A1, B0, B1, B2) and a temporal merge candidate ("Col") using corresponding "availableFlag" variables. WD4 then constructs the list using only the available candidates. Petitioner further contended that WD4 discloses adding additional candidates (e.g., zero motion vector candidates) if the number of available candidates is below a predetermined maximum of five. Crucially, for limitation 1(h) concerning asymmetric partitioning, Petitioner argued that WD4's processing rules for vertical asymmetric partitioning (e.g., PART_nLx2N) explicitly render the spatial merge candidate from the first partition (e.g., candidate A1) unavailable when processing the second partition, thereby directly teaching the claimed rule. Petitioner also mapped dependent claims 2-7 to specific sections of WD4, arguing for example that claim 6, which disallows asymmetric partitioning for a coding unit of a minimum size, was disclosed by a binarization table in WD4 where code words for asymmetric partitions are undefined when the coding unit size equals the minimum allowed size.

Ground 2: Claims 1-7 are obvious under 35 U.S.C. §103 over WD4 in view of Han.

  • Prior Art Relied Upon: WD4 and Han (Han et al., "Improved Video Compression Efficiency Through Flexible Unit Representation and Corresponding Extension of Coding Tools," an IEEE journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, primarily addressing the potential argument that WD4 does not use the express term "asymmetric partitioning" as required by claim 1(h), even if it describes the functionality. Petitioner asserted that WD4 teaches all limitations, and Han was introduced to supply the explicit disclosure and definition of partition modes like nLx2N and nRx2N as being "asymmetric."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Han's explicit teaching of asymmetric partitions with the merge candidate process in WD4 to improve the coding efficiency of irregular object boundaries, a well-known problem in video compression. The motivation was strong because both references were part of the same HEVC standardization effort, addressed the same technical challenges, and Han's corresponding proposal (JCTVC-A124) was referenced in documents incorporated into WD4.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in the combination. Implementing Han's defined asymmetric partitions into WD4's framework was argued to be a predictable design choice, as it involved applying a known technique to an existing system to achieve the predictable result of improved compression, without requiring undue experimentation.

4. Key Technical Contentions (Beyond Claim Construction)

  • Ineffective Priority Claim: A central contention underpinning both grounds was that the ’772 patent was not entitled to its claimed priority date of November 7, 2011, from a Korean application (’219 KR application). This argument was critical for establishing that WD4 (published October 4, 2011) and Han (published December 2010) qualify as prior art. Petitioner asserted two primary defects in the priority claim:
    • Lack of Common Inventorship: US law requires that a foreign priority application and the subsequent US application share at least one common inventor. Petitioner presented evidence showing the sole inventor of the ’219 KR application was Min Jang, while the inventors of the ’772 patent are Soo Mi Oh and Moonock Yang, with no overlap.
    • Lack of Written Description Support: As a secondary argument, Petitioner contended that the ’219 KR application fails to provide adequate written description support for the subject matter of claims 5 and 6. Specifically, it allegedly fails to disclose that prediction unit size is determined based on a "partitioning mode" (claim 5) or that asymmetric partitioning is disallowed when a coding unit is at its minimum allowed size (claim 6).

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-7 of the ’772 patent as unpatentable.