PTAB

IPR2017-01848

Vizio Inc v. LighTSIde Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Format Audio/Video Production System
  • Brief Description: The ’727 patent relates to a multi-format audio/video production system (M.A.P.S.) that uses general-purpose computer hardware to perform format conversions and produce high-quality HDTV-format programming from various input sources. The system is designed to handle different frame rates and pixel resolutions, converting content for display on HDTVs.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4, 11, and 14 are obvious over Washino in view of Richards.

  • Prior Art Relied Upon: Washino (Patent 5,537,157) and Richards (Patent 5,208,669).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Washino disclosed a multi-format video production system nearly identical to the ’727 patent’s M.A.P.S. Washino taught receiving video content, decompressing it into a 24 frames per second (fps) internal format, processing it for frame-rate conversion (e.g., to 30 fps), and outputting a high-resolution progressive HDTV signal. However, Petitioner contended that Washino did not explicitly teach a memory buffer with asynchronous read/write capabilities for continuous frame-rate conversion. This limitation was allegedly supplied by Richards, which disclosed a video production system with a high-definition digital frame recorder (HDDFR). The HDDFR system used a pair of memory buffers operating in an alternating, or "ping-pong," fashion to continuously store input frames at one rate while simultaneously outputting previously stored frames at a different, asynchronous rate.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine these references because both Washino and Richards are analogous art directed to video format converters. Petitioner asserted that Washino expressly identified a need for “more sophisticated frame-rate conversion techniques” to handle live television broadcasts where input and output rates differ. Richards directly addressed this problem by teaching a dual-buffer system for continuous, asynchronous conversion, making it a natural solution for a POSITA seeking to improve Washino’s system.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as implementing the well-known dual-buffer storage architecture from Richards into Washino’s PC-based system was a predictable integration. It involved applying a known technique to achieve the known, desired result of continuous frame-rate conversion.

Ground 2: Claims 2 and 12 are obvious over Washino in view of Richards and Faroudja.

  • Prior Art Relied Upon: Washino (Patent 5,537,157), Richards (Patent 5,208,669), and Faroudja (Patent 6,222,589).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the combination from Ground 1 and added Faroudja to teach the specific limitation of repeating each frame an integer multiple of times. This technique is used to generate an output frame rate that is an integer multiple of the 24 fps input format. Petitioner argued that Faroudja taught an "improved signal processing apparatus" that explicitly repeated input frames (from sources like a 24 fps film) at least twice using a two-frame memory buffer. This process allowed Faroudja's system to generate a higher, smoother output frame rate (e.g., up to 120 fps) "substantially without motion discontinuities."
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to add Faroudja’s technique to the Washino/Richards system to achieve higher quality, higher frame rate output. Washino’s stated goal was a high-quality, flexible system, and Faroudja taught a simple, known method for increasing frame rates while avoiding motion artifacts. This provided a clear and desirable improvement. The components needed to perform this frame repetition—a processor and a memory buffer—were already present in the Washino/Richards combination.
    • Expectation of Success (for §103 grounds): Success was predictable because implementing Faroudja's frame-repetition logic was merely applying a known video processing technique to the existing hardware taught by Washino and Richards. No significant modification or undue experimentation would have been required.

4. Key Claim Construction Positions

  • Petitioner argued that the term "means for at least one of receiving or retrieving compressed video data" recited in claim 11 is a means-plus-function limitation subject to pre-AIA 35 U.S.C. §112, sixth paragraph.
  • Petitioner identified the claimed function as "at least one of receiving or retrieving compressed video data." The corresponding structure disclosed in the ’727 patent specification for performing this function was identified as an over-the-air antenna, satellite receivers, and a high-bandwidth data network interface, which provide signals to a decompression processor. This construction was central to mapping the prior art, which disclosed similar input structures.

5. Key Technical Contentions (Beyond Claim Construction)

  • A central contention of the petition was that the challenged claims were not entitled to the ’727 patent’s earliest claimed priority date (May 7, 1998).
  • Petitioner argued that the claim limitation "a high-capacity memory buffer supporting asynchronous random read and write access" constituted new matter added during a 2014 amendment. To support this, Petitioner cited the prosecution history of a related patent (’198 patent) where the applicant allegedly characterized a similar limitation as "new matter" to overcome a rejection over Washino. By asserting this, Petitioner argued that the effective filing date for the challenged claims was much later, ensuring that Washino, Richards, and Faroudja all qualified as prior art under 35 U.S.C. §102.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 4, 11, 12, and 14 of Patent 8,842,727 as unpatentable.