PTAB

IPR2017-00347

Samsung Electronics Co Ltd v. Image Processing Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Process and Apparatus for Identifying a Target in an Input Signal
  • Brief Description: The ’001 patent discloses a process for identifying and tracking a target within a video signal by generating and analyzing one or more histograms derived from pixel characteristics in an image frame.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gilbert and Hashima - Claims 1-4 are obvious over Gilbert in view of Hashima.

  • Prior Art Relied Upon: Gilbert (A Real-Time Video Tracking System, Jan. 1980 journal article) and Hashima (Patent 5,521,843).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gilbert, a 1980 article on real-time video tracking, discloses the core process of claim 1: tracking a target in a video signal on a frame-by-frame basis by generating histograms. Gilbert’s system uses histograms based on pixel intensity (grayscale) to separate a target from its background and also creates X- and Y-projections from a binary image to locate the target. Petitioner asserted that Hashima, which teaches a system for recognizing and tracking a target mark, explicitly discloses generating X- and Y-domain histograms and, crucially, determining the target's center by calculating the midpoint between the X- and Y-minima and maxima from those histograms. This method is identical to that described in the ’001 patent and directly maps to the limitations of claims 1 and 2. Petitioner contended that dependent claims 3 (determining the center at regular intervals) and 4 (drawing a tracking box) are also taught by the combination.
    • Motivation to Combine: A POSITA would combine these references because they address analogous problems in the same field of image tracking. Petitioner argued a POSITA would look to improve Gilbert’s complex center-of-area calculation with Hashima’s simpler, more computationally efficient method of using histogram minima and maxima to find the target's center. This modification would increase processing speed and reduce hardware costs while achieving the same goal of locating the target for tracking.
    • Expectation of Success: A POSITA would have had a high expectation of success because combining the known technique of center-finding from Hashima with the established tracking framework of Gilbert involved applying predictable solutions to improve a known system.

Ground 2: Obviousness over Hashima and Ueno - Claims 1-4 are obvious over Hashima in view of Ueno.

  • Prior Art Relied Upon: Hashima (Patent 5,521,843) and Ueno (Patent 5,150,432).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Hashima teaches the majority of the limitations in the independent claim, including frame-by-frame processing of a video signal, generating X- and Y-projected histograms to identify a target, and determining the target's center from the minima and maxima of those histograms. However, Petitioner argued that Ueno, which describes tracking a human facial region, provides a stronger disclosure for the limitation of drawing a tracking box around the target, as required by claim 4. Ueno explicitly teaches specifying the detected facial region by a "rectangle designated by coordinates Xs, Xe, Ys, and Ye" and displaying this frame superimposed on the image on a monitor.
    • Motivation to Combine: A POSITA would combine Hashima with Ueno to improve the user interface and functionality of Hashima’s system. While Hashima’s system tracks a target, it does not explicitly teach a method for highlighting the target for easy visualization by a user. Petitioner argued that adding a tracking box, as taught by Ueno, is a common and advantageous feature that allows a user to visually confirm that the correct object is being tracked. This would have been a simple and desirable addition to make Hashima's system more user-friendly.
    • Expectation of Success: The combination would predictably result in a system that both tracks a target using histograms (from Hashima) and visually highlights that target with a bounding box (from Ueno), which was a straightforward integration of known elements.

Ground 3: Obviousness over Ueno and Gilbert - Claims 1-4 are obvious over Ueno in view of Gilbert.

  • Prior Art Relied Upon: Ueno (Patent 5,150,432) and Gilbert (a 1980 journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ueno discloses a system that tracks a target (a face) using X- and Y-histograms derived from interframe differences and draws a tracking box around it. Ueno thus teaches the core elements of claims 1 and 4. Petitioner then turned to Gilbert to supply the teaching of automatically tracking a target by physically adjusting the camera. Gilbert explicitly teaches using the calculated target center to provide "boresight correction signals" that control the "azimuth and elevation pointing angles of the telescope...keeping the target visible within the FOV." This provides the functionality of active camera tracking that Ueno lacks. Gilbert also suggests, as one option, calculating the target center using "target nose and tail points," which are analogous to the X- and Y-minima and maxima.
    • Motivation to Combine: A POSITA would combine Ueno with Gilbert to add a significant feature: active camera tracking. Ueno's system identifies a target within a stationary camera's field of view but does not teach moving the camera to follow the target. A POSITA seeking to create a more robust tracking system would have been motivated to incorporate an active camera control mechanism. Gilbert provides an exemplary system for doing exactly this, using the calculated center of a target to control servomotors and keep the target centered in the frame. This combination would transform Ueno’s static detection system into a dynamic tracking system.
    • Expectation of Success: A POSITA would have reasonably expected success in integrating Gilbert's established camera control logic into Ueno's target detection framework, as it involved combining complementary technologies to achieve a more capable and functional system.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-4 of Patent 8,805,001 as unpatentable.