PTAB

IPR2018-00238

ZTE Corporation v. Maxell, Ltd.

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1. Case Identification

2. Patent Overview

  • Title: ELECTRIC CAMERA
  • Brief Description: The ’729 patent is directed to an electric camera system capable of operating in distinct modes. The system is designed to capture high-resolution still images using a first set of effective pixels and a first view angle, and to capture moving video images, typically at a lower quality, using a second set of effective pixels and a different view angle, while also incorporating image stabilization technology.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 3 are obvious over Parulski ‘406, Parulski ‘343, and Ishizuka ‘192.

  • Prior Art Relied Upon: Parulski ‘406 (Patent 5,828,406), Parulski ‘343 (Patent 5,440,343), and Ishizuka ‘192 (Patent 5,497,192).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Parulski ‘406 teaches an electronic camera with a dual-mode operation for capturing high-quality still images and lower-quality motion preview images, including an image sensor with a pixel array and a signal processing unit. To add the claimed user-selectable mode functionality, Petitioner argued that a person of ordinary skill in the art (POSITA) would look to Parulski ‘343, which explicitly teaches a mode selection switch for a camera that records both motion and still images. To address the well-known problem of camera shake, Petitioner contended a POSITA would incorporate the image stabilization system from Ishizuka ‘192, which discloses using pitch and yaw angular velocity sensors to detect and correct for image instability.
    • Motivation to Combine: A POSITA would combine Parulski ‘406 with Parulski ‘343 (which shares a common inventor) to implement a user-friendly mode selection interface, a known design choice for improving usability in multi-function devices. The motivation to add Ishizuka’s stabilization technology was to solve the known problem of image instability, thereby improving image quality, a predictable and desirable enhancement for any digital camera.
    • Expectation of Success: Petitioner argued that combining these known elements would have been a straightforward integration of conventional components for their intended functions, presenting a high expectation of success.

Ground 2: Claims 1 and 3 are obvious over Dunton ‘541, Parulski ‘335, and Ishizuka ‘192.

  • Prior Art Relied Upon: Dunton ‘541 (Patent 6,512,541), Parulski ‘335 (Patent 5,493,335), and Ishizuka ‘192 (Patent 5,497,192).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Dunton ‘541 serves as an alternative primary reference, teaching an imaging apparatus with distinct still and video modes where the video mode uses lower resolution to achieve a wider angular field of view. To incorporate the claimed display unit and user-selectable operations, Petitioner argued a POSITA would have incorporated the teachings of Parulski ‘335, which discloses a camera with a display unit (LCD) and a resolution mode switch allowing a user to select a full resolution mode using all pixels. As in the first ground, Ishizuka ‘192 was cited for its teaching of an image-instability detector that corrects for camera shake by shifting the effective pixel area.
    • Motivation to Combine: A POSITA would combine Dunton ‘541 with Parulski ‘335 to provide a necessary display screen for image review and a user interface for selecting different resolution modes, which are routine features for enhancing camera functionality. The motivation to incorporate Ishizuka ‘192 remained the same: to improve image quality by adding a known solution for image stabilization.
    • Expectation of Success: Petitioner asserted that integrating a display, user controls, and image stabilization into the camera system of Dunton ‘541 represented a predictable combination of established technologies, and a POSITA would have had a reasonable expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for dependent claims 2 and 4 based on Parulski ‘406 alone (Ground B) and Dunton ‘541 alone (Ground D). These grounds argued that the references inherently teach or suggest a camera where the first view angle (for still images) is larger than the second view angle (for video images), or that this would have been an obvious design choice for a POSITA to implement using the disclosed zoom functionalities.

4. Key Claim Construction Positions

Petitioner proposed several constructions under the broadest reasonable interpretation standard, arguing they were critical to the obviousness analysis.

  • "an image instability detector": Petitioner asserted this term should be construed functionally as a component for "detecting an image-instability of the electric camera." This broad functional definition was important for mapping the angular velocity sensors of Ishizuka ‘192 to the claim limitation.
  • "to change a position of the second effective set of pixels ... to correct the image-instability": Petitioner argued this should be construed to mean that "the position of an extracted area (effective pixel area) on the light receiving surface is shifted in a direction that cancels the image-instability." This construction aligns with the mechanism described in Ishizuka ‘192 for correcting camera shake.
  • "a display unit": Petitioner proposed construing this term as a "display screen of a television system," such as one compatible with NTSC or PAL formats. This construction was based on the specification's examples and was used to map the display elements taught in references like Parulski ‘335.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4 of the ’729 patent as unpatentable.