PTAB

IPR2017-01218

Samsung Electronics Co Ltd v. Image Processing Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Process and Apparatus for Tracking a Target in a Video Signal
  • Brief Description: The ’134 patent discloses a process for identifying and tracking a target within an input signal, such as a video feed, by generating and analyzing one or more histograms. The system uses pixel characteristics, or "domains" (e.g., luminance, speed, position), to construct these histograms and identify the target on a frame-by-frame basis.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gerhardt and Bassman - Claims 3-6 are obvious over Gerhardt in view of Bassman.

  • Prior Art Relied Upon: Gerhardt (Patent 5,481,622) and Bassman (Patent 6,044,166).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Gerhardt and Bassman taught all limitations of the challenged claims. Gerhardt disclosed a process for tracking a target (a user's pupil) using an image processing system that analyzes video frames. It formed intensity histograms to identify the target, located blobs of contiguous pixels, and determined X/Y minima and maxima to define a bounding rectangle. Gerhardt also disclosed key dependent claim limitations, including increasing the size of a selected "active window" until the target is found (claim 4) and using system components like memory and temporal/spatial processing units (claim 3). Bassman, which tracked vehicles on a roadway, taught a similar frame-by-frame process using histograms and comparing pixel intensity values between successive frames to maintain tracking.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Gerhardt and Bassman as they address similar problems in the same field of image processing and tracking. A POSITA would have recognized that Bassman’s method of explicitly linking a target’s position from a previous frame to a current one could improve the reliability of a system like Gerhardt’s. This combination would reduce false positives (e.g., when a user blinks in Gerhardt’s eye-tracking system) and increase processing speed by more quickly eliminating irrelevant pixel data, yielding a predictable improvement.
    • Expectation of Success: Petitioner contended a POSITA would have a reasonable expectation of success because the combination involved applying known techniques for improving target tracking to similar, well-understood image processing systems.

Ground 2: Obviousness over Gilbert, Gerhardt, and Hashima - Claims 3-6 are obvious over Gilbert in view of Gerhardt and further in view of Hashima.

  • Prior Art Relied Upon: Gilbert (a 1980 journal article titled A Real-Time Video Tracking System), Gerhardt (Patent 5,481,622), and Hashima (Patent 5,521,843).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted this three-way combination rendered claims 3-6 obvious. Gilbert, the primary reference, described a real-time system for tracking missiles and aircraft using a video processor that generated intensity and projection histograms within a tracking window. Gilbert taught identifying a target from these histograms and adjusting the camera optics to follow it. Gerhardt was cited for its teaching of an "adaptive thresholding technique" robust to changing light conditions, which could improve Gilbert's histogram-based identification. Hashima was cited for its simpler, more efficient method of calculating a target's center using the X/Y minima and maxima from projected histograms. This combination collectively taught forming histograms, identifying the target, determining its boundaries, and adjusting a selected area until the target is found, as required by the challenged claims.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to combine these references to improve upon a system like Gilbert’s. A POSITA would incorporate Gerhardt's adaptive thresholding to make Gilbert's system more robust and faster in varying lighting conditions. Further, a POSITA would replace Gilbert’s computationally complex method for determining target orientation (splitting the target into halves) with Hashima’s simpler and more efficient method of calculating the center from X/Y minima and maxima. This modification would reduce computational burden and hardware expense while achieving the same goal of tracking a target.
    • Expectation of Success: A POSITA would have reasonably expected success in this combination, as it involved substituting known, simpler, and more efficient techniques (from Gerhardt and Hashima) into an established system (Gilbert) to achieve predictable improvements in performance and efficiency.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that this petition was not redundant to an earlier-filed IPR (IPR2017-00353) against the same ’134 patent. This second petition was necessitated because the Patent Owner amended its infringement contentions in parallel district court litigation to assert new claims (the challenged claims 3-6). Petitioner asserted this filing was a prompt response to address these newly-added claims. Furthermore, Petitioner stated that this petition raises new arguments and relies on different prior art combinations not presented in the earlier petition, and therefore should not be subject to discretionary denial.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 3-6 of Patent 8,983,134 as unpatentable.