PTAB

IPR2017-00437

Google Inc v. Koninklijke Philips NV

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Petition
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1. Case Identification

2. Patent Overview

  • Title: High Frequency and Low Frequency Audio Signal Encoding and Decoding System
  • Brief Description: The ’114 patent discloses a transmission system for digital audio signals. The system splits an input audio signal into a low-frequency band and a high-frequency band, which are then encoded separately using different techniques to improve compression efficiency before transmission and subsequent decoding.

3. Grounds for Unpatentability

Ground 1: Claims 10-15 and 20 are anticipated by Tucker

  • Prior Art Relied Upon: Tucker (International Publication No. WO 98/52187).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tucker discloses every limitation of independent claims 10 and 20, as well as dependent claims 11-15. Tucker describes a wideband transmission system that splits an audio signal into lower and upper sub-bands using low-pass and high-pass filters. For the low band, Tucker uses a generic "off-the-shelf" narrowband decoder, which Petitioner mapped to the '114 patent's "first decoder." For the high band, Tucker’s decoder uses a white noise source that is processed sequentially by a "spectral shaping filter" (an LPC synthesis filter), a gain multiplier (an amplifier), and a processor that "reflects" the signal to the upper band (a high-pass filter). Petitioner contended this arrangement meets the claim limitation requiring a second decoder that "sequentially applies" these components to a noise signal.
    • Key Aspects: The argument for anticipation relies heavily on the construction of "sequentially," which Petitioner asserted does not require the specific order recited in the claims (see Section 4). Petitioner also mapped Tucker's disclosure of a "decimator" and narrowband encoder to the down-sampler requirement of claim 11, and its "spectral & noise analysis" to the measurement of signal strength (claim 12), generation of amplification codes (claim 13), and determination of prediction coefficients (claim 14).

Ground 2: Claims 10-16 and 20-21 are obvious over Tucker in view of Well-Known Art

  • Prior Art Relied Upon: Tucker (WO 98/52187) and the general knowledge of a person of ordinary skill in the art (POSITA).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to anticipation. If the Board were to find that the term "sequentially applies" requires the exact order of components recited in the claims (high-pass filter, then LPC synthesis filter, then amplifier), Petitioner argued that Tucker’s disclosure renders this arrangement obvious. Tucker teaches the same three components but applies them in a different order (LPC filter, then amplifier, then high-pass filter). Furthermore, Petitioner contended that adding a delay to align signals before combining them (as required by claims 16 and 21) was a well-known and obvious technique not expressly taught by Tucker but readily apparent to a POSITA.
    • Motivation to Combine: A POSITA would have understood that the high-pass filter, LPC synthesis filter, and amplifier are linear time-invariant components, meaning the order of their application to a noise signal is inconsequential and does not affect the final output. Therefore, a POSITA would find it obvious to rearrange the components disclosed in Tucker into the order recited by the claims as a matter of simple design choice. For claims 16 and 21, a POSITA would be motivated to add a delay to align the low and high band signals before combining them to prevent distortion, a fundamental and routine practice in signal processing.
    • Expectation of Success: There would have been a high expectation of success in rearranging the filter components, as the predictable nature of linear time-invariant systems ensures the outcome would be the same. Similarly, adding a standard delay for signal alignment is a straightforward task with a predictable and successful outcome.

4. Key Claim Construction Positions

  • Petitioner argued for a Broadest Reasonable Interpretation (BRI) of the phrase "second decoder sequentially applies a high-pass filter, a LPC synthesis filter and an amplifier to a noise signal" (claims 10 and 20).
  • Petitioner’s proposed construction was "applying a high-pass filter, a LPC synthesis filter and an amplifier to a noise signal one at a time," without being limited to the precise order recited in the claim. This interpretation was central to the anticipation argument (Ground 1), as Tucker discloses these three components being applied sequentially but in a different order. Petitioner supported this by noting the specification does not use the word "sequentially" or otherwise require a specific order, and that the order is technically inconsequential.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 10-16 and 20-21 of the ’114 patent as unpatentable.