PTAB

IPR2017-00683

LG Electronics Inc v. FastVDO LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Data Encoding Method and Apparatus
  • Brief Description: The ’482 patent discloses a method and apparatus for error-resilient data encoding combining source and channel coding techniques. The core of the invention is a "split-field coding" method where data is encoded into code words comprising a first portion (prefix) and a second portion (suffix), with unequal error protection applied to more robustly shield the critical prefix field from transmission or storage errors.

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 discloses every key limitation of the challenged claims. Kato describes a split-field coding scheme where input data is encoded into code words having a first portion (Pi) and a second portion (Ri). Critically, Kato's first portion includes data representing the bit length of the code word, which is used by the decoder to identify word boundaries. Kato further discloses applying higher error protection to the first portions than to the second portions to mitigate the propagation of errors, directly mapping to the central concept of the ’482 patent. The patent also discloses standard data compression steps like transforming and quantizing data.
    • Motivation to Combine (N/A): As a single-reference ground, the argument focused on Kato’s direct disclosures and what they would have rendered obvious. Petitioner contended that any minor differences between Kato and the claims, such as whether the prefix encodes the length of the entire code word versus just the suffix, represent simple and obvious design choices. For example, modifying Kato's prefix to directly represent the suffix length (L2) instead of the total length (L1+L2) was argued to be a simple substitution of one known element for another to obtain a predictable result.
    • Expectation of Success: A person of ordinary skill in the art (POSITA) would have had a clear expectation of success in implementing the claimed methods and apparatus based on Kato’s detailed teachings on split-field coding and unequal error protection.

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 publication), Fazel (a 1990 IEEE publication), and Fazel ’622 (Patent 5,218,622).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Fiala, which is admitted prior art in the ’482 patent itself, teaches the foundational split-field coding method where a prefix (e.g., a unary code) is used to specify the length of a following suffix. The Fazel references (the paper and the patent) teach the principle of unequal error protection (UEP), specifically disclosing that for reliable communication over noisy channels, the most important information in a data stream (such as frame length data needed for synchronization) must be protected more efficiently than less critical data.
    • Motivation to Combine: A POSITA, starting with Fiala's known split-field coding scheme for data compression, would combine it with the UEP teachings of Fazel and Fazel ’622 to solve the well-known problem of error propagation. The motivation was to improve the robustness of the compressed data for transmission or storage. A POSITA would have recognized that the prefix in Fiala's scheme, which contains the critical length information, is the most important data for decoding and would have been motivated to apply the stronger error protection taught by Fazel to that prefix.
    • Expectation of Success: The combination was presented as the application of a known technique (UEP) to a known method (split-field coding) to achieve the predictable and desired result of enhanced error resilience. A POSITA would therefore have had a high expectation of success.

4. Key Claim Construction Positions

  • Petitioner dedicated a substantial portion of the petition to arguing that numerous means-plus-function limitations in the challenged claims are indefinite under 35 U.S.C. §112 for failing to disclose adequate corresponding structure or algorithms in the ’482 patent specification.
  • "Error protection means" (Claims 7, 22): Petitioner argued this term is indefinite because the specification does not disclose any structure for performing the function. Instead, it merely states that methods for unequal error protection were "known to those skilled in the art" and provides a citation to a 600-page textbook, which Petitioner contended is insufficient to constitute a disclosure of corresponding structure.
  • "Code word generating means" / "Entropy coding means" (Claims 7-8, 22-23): For these and related terms, Petitioner argued that while the specification describes their function, it fails to disclose any specific algorithm for a computer to execute. Since the functions are described as being implemented by a computer or controller, the lack of a disclosed algorithm renders the claims indefinite.

5. Relief Requested

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