PTAB

IPR2017-01217

Samsung Electronics Co Ltd v. Image Processing Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Identifying and Tracking a Target
  • Brief Description: The ’445 patent discloses a method for identifying and tracking a target within a video signal. The system generates and analyzes histograms based on pixel characteristics from successive video frames to determine a target's location and movement.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gilbert, Brady, and Gil - Claims 2, 3, 5, 7, 8, 10-16, 19-22, 26, and 30 are obvious over Gilbert in view of Brady and Gil.

  • Prior Art Relied Upon: Gilbert (a 1980 journal article titled A Real-Time Video Tracking System), Brady (Patent 5,761,326), and Gil (a 1994 article titled Feature selection for object tracking in traffic scenes).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary combination of Gilbert and Brady disclosed the core limitations of the independent claims, including tracking a target using a video input, generating histograms from video frames, and identifying and adjusting the target's location frame-by-frame. Gilbert taught a real-time missile tracking system using intensity and projection histograms. Brady taught a vehicle tracking system using more advanced "edgel intensity" histograms. Petitioner contended that Gil supplemented this combination by teaching specific dependent claim features, such as determining target speed and direction using Kalman filters and state vector matrices (claims 10-11), identifying a non-moving background area (claim 13), and refining an outline to fit a target's contours (claim 26).
    • Motivation to Combine: A POSITA would combine Gilbert and Brady because they address nearly identical problems (video target tracking) using similar means (histograms). The POSITA would have been motivated to improve Gilbert’s older system by incorporating Brady's more efficient "edgel intensity" histogram technique for better edge detection. A POSITA would further incorporate Gil to add well-known features like velocity calculation and adaptive outlining, and to implement Kalman filtering, a technique Gilbert had considered but found computationally prohibitive in 1980.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying known and compatible video processing techniques from the same field of endeavor to achieve predictable improvements in performance and functionality.

Ground 2: Obviousness over Gilbert, Brady, and Ueno - Claims 16, 17, and 23 are obvious over Gilbert in view of Brady and Ueno.

  • Prior Art Relied Upon: Gilbert, Brady (’326 patent), and Ueno (Patent 5,150,432).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on the same base combination of Gilbert and Brady, but added Ueno to disclose features related to user interaction and specific target types. Petitioner argued that Ueno, which taught a system for tracking human faces, explicitly disclosed receiving user input via a mouse or keyboard to designate a target within a video frame (claims 16-17). Ueno’s primary purpose was to detect a "facial region," directly teaching the limitation that the target is a face (claim 23).
    • Motivation to Combine: A POSITA would combine the Gilbert/Brady system with Ueno to add user-input functionality, a common feature in image processing systems. Furthermore, a POSITA would have been motivated to improve Ueno’s stationary camera system by incorporating Gilbert’s teachings on calculating a target's center and dynamically adjusting the camera optics to follow the target. This would add valuable functionality, such as tracking a person moving during a video conference.
    • Expectation of Success: The combination involved integrating a known user-interface method (from Ueno) with a known automatic tracking system (from Gilbert/Brady), which would have been a straightforward and predictable integration for a POSITA.

Ground 3: Obviousness over Gilbert, Brady, Ueno, and Gil - Claims 28 and 29 are obvious over Gilbert in view of Brady, Ueno, and Gil.

  • Prior Art Relied Upon: Gilbert, Brady (’326 patent), Ueno (’432 patent), and Gil.
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground combined all four references to address system claims requiring user input of a center position. Petitioner asserted that Ueno taught receiving user input to define a bounding box, while Gil taught tracking based on a target’s centroid (center point). The combination of these teachings rendered it obvious to configure a system to receive user input designating a center position for the target (claim 28). The subsequent limitation of determining an updated center position based on histograms from subsequent frames (claim 29) was taught by Gilbert, which calculated a target's center-of-area point on a frame-by-frame basis.
    • Motivation to Combine: A POSITA would have been motivated to modify Ueno's bounding-box input method with Gil's more precise centroid-based approach. This would be a simple design choice to improve usability by allowing a user to simply click on the center of a target rather than drawing a box around it. The motivation to then update this center position using Gilbert’s methods follows from the desire to track the user-selected target over time.
    • Expectation of Success: Modifying a user-input method from a bounding box to a center point was presented as a simple and predictable design choice, and combining it with an established frame-by-frame tracking algorithm would have yielded a successful result.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that this petition was not redundant to a concurrently filed petition (IPR2017-01212) or an earlier-filed petition (IPR2017-00357). Petitioner contended this IPR was necessary because the Patent Owner had asserted new claims during a parallel district court litigation after the first petition was filed. This petition addresses those newly-asserted claims and relies on different prior art combinations and arguments not previously presented to the Board, justifying institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 2, 3, 5, 7, 8, 10-17, 19-23, 26, and 28-30 of the ’445 patent as unpatentable.