PTAB

IPR2017-01675

LG Electronics, Inc. v. Broadcom Corporation

Log In

1. Case Identification

2. Patent Overview

  • Title: Graphics Display System with Anti-flutter Filtering and Vertical Scaling Feature
  • Brief Description: The ’104 patent describes a graphics processing system for blending graphics and video images for simultaneous display. The patent’s asserted novelty lies in a “two-step process” where multiple graphics images are first blended together using their respective alpha (opacity) values to create an intermediate blended graphics image (BGI), which is then blended with a background video image.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gloudemans and Blinn - Claims 1, 10, 11, 16, 17, and 22 are obvious over Gloudemans in view of Blinn.

  • Prior Art Relied Upon: Gloudemans (Patent 6,266,100) and Blinn (IEEE Computer Graphics & Applications, Sep 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gloudemans discloses a system for enhancing live video broadcasts (e.g., football) by blending graphics, such as a first-down line or a logo, with the video feed using processors and memory. While Gloudemans teaches blending a single graphic layer with video, Blinn, a seminal paper on compositing theory, explicitly teaches that alpha blending is mathematically associative. This principle allows multiple foreground images to be pre-blended into an intermediate image with a newly derived composite alpha value, which can then be blended with a background. Petitioner contended that applying Blinn’s well-known theory to Gloudemans’ system would result in the ’104 patent’s claimed two-step process.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to improve system efficiency and the viewer experience. In Gloudemans' football example, where multiple graphics like a score box and a first-down line might overlap, a POSITA would be motivated by Blinn’s teaching to blend these graphics together first. This approach would minimize processing delay in a live broadcast, conserve resources by requiring only a single final blend with the video, and allow processing like scaling to be performed once on the pre-blended graphic.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination merely applies a known mathematical principle (Blinn's associative compositing) to a known type of graphics system (Gloudemans). The implementation would involve predictable modifications to the software running on the computers already disclosed in Gloudemans.

Ground 2: Obviousness over Myhrvold and Blinn - Claims 1, 10, 11, 16, 17, and 22 are obvious over Myhrvold in view of Blinn.

  • Prior Art Relied Upon: Myhrvold (Patent 5,867,166) and Blinn (IEEE Computer Graphics & Applications, Sep 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Myhrvold teaches an image processing system that composites multiple graphics layers (called “gsprites”) to create a final image for display. Myhrvold’s system blends these gsprites and accumulates their opacity in an “alpha buffer,” which is functionally equivalent to the ’104 patent’s first step of creating a blended graphics image with a composite alpha value. Blinn provides the explicit teaching and rationale for using such a pre-blended image and its derived composite alpha value for a subsequent blend with a background image, rendering the claimed two-step process obvious.
    • Motivation to Combine: A POSITA would be motivated to apply Blinn’s teachings to Myhrvold’s system to logically complete the compositing process for video applications. Since Myhrvold already discloses combining graphics and video and its alpha buffer already stores the composite alpha value from the gsprite blend, it would have been a natural and predictable step to use that value to blend the composite graphic onto a video background, as taught by Blinn, to ensure correct transparency.
    • Expectation of Success: Success would be reasonably expected because the combination leverages the existing architecture of Myhrvold. The system’s alpha buffer already calculates and stores the necessary composite alpha value, making its use in a final blending step with video—as explained by Blinn—a straightforward application of the system’s inherent capabilities.

4. Key Claim Construction Positions

  • Petitioner argued that the challenged claims are obvious regardless of the specific construction applied. It noted that the claims are unpatentable under constructions previously adopted by a district court in related litigation, constructions proposed by the Patent Owner in that litigation, and the plain and ordinary meaning of the terms. Key terms discussed included “blended graphics image,” defined as a mixture of at least two graphics images, and “a plurality of alpha values.”

5. Key Technical Contentions (Beyond Claim Construction)

  • The petition’s central technical argument was that alpha blending is mathematically associative, a fundamental principle in computer graphics well-known before the patent’s priority date. Petitioner contended that the ’104 patent’s claimed “two-step process” (pre-blending graphics, then blending with video) was therefore not a patentable invention but merely one of three logical and obvious design choices available to a POSITA, all of which were known techniques at the time.

6. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1, 10, 11, 16, 17, and 22 as unpatentable.