PTAB

IPR2018-00477

LG Electronics Inc v. Broadcom Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: VIDEO DECODING SYSTEM SUPPORTING MULTIPLE STANDARDS
  • Brief Description: The ’844 patent discloses systems for decoding digital video data that support multiple video standards. The system comprises a processor adapted to control the decoding process and a hardware accelerator coupled to the processor, where the accelerator is configurable to perform a decoding function according to a plurality of decoding methods.

3. Grounds for Unpatentability

Ground 1: Claims 1-14 are anticipated by Fandrianto ’459 under 35 U.S.C. §102.

  • Prior Art Relied Upon: Fandrianto ’459 (Patent 5,982,459).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fandrianto ’459 disclosed a digital media decoding system that met every limitation of independent claim 1 and the asserted dependent claims. The system's supervisory RISC processor 220 was described as controlling the overall decoding process, including bit stream parsing. The ’459 patent further disclosed at least three distinct hardware accelerators coupled to this processor: (1) a video processor 280, (2) a Huffman codec 260, and (3) an H.221/BCH decoder 240. Petitioner contended these dedicated hardware units qualified as "accelerators" because they enhanced specific decoding tasks. For the final limitation of claim 1, Petitioner argued these accelerators were configurable to perform decoding according to a plurality of methods, noting that video processor 280 was a programmable signal processor that implemented functions like inverse DCTs and scaling as required by software-selected standards like MPEG, JPEG, and H.261. Petitioner asserted that the disclosure of three distinct accelerators met the "plurality of hardware accelerators" limitation of dependent claims 3 and 10. For claim 11, Petitioner mapped the Huffman codec 260 to the claimed "programmable entropy decoder" and the video processor 280 to the claimed "inverse quantizer," "inverse transform accelerator," "pixel filter," and "motion compensator" limitations.

Ground 2: Claims 1-4, 6-11, and 13-14 are anticipated by Fandrianto ’842 under 35 U.S.C. §102.

  • Prior Art Relied Upon: Fandrianto ’842 (Patent 6,441,842).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fandrianto ’842 independently anticipated the claims by disclosing a video decoding system centered on a vision processor 100. This processor controlled the decoding process and included a plurality of integrated accelerators: a Control Section 90, a Motion Estimation Section 92, and a Discrete Cosine Transform (DCT) Section 94. These sections contained dedicated hardware like a RISC-type controller, shifters, and multiplier-accumulator (MAC) units to perform decoding steps such as inverse quantization and inverse DCT on a streaming video data. The system was argued to be configurable to perform decoding according to a plurality of methods because it operated in at least two different modes (intraframe and predictive) and was explicitly described as being reconfigurable to operate according to various industry-recognized video-coding standards. For dependent claim 11, Petitioner mapped ’842's arithmetic units to the entropy decoder, its MAC units to the inverse quantizer and inverse transform accelerator, and its shifter units to the motion compensator.

Ground 3: Claims 11-14 are obvious over Fandrianto ’459 in view of Fandrianto ’842.

  • Prior Art Relied Upon: Fandrianto ’459 (Patent 5,982,459) and Fandrianto ’842 (Patent 6,441,842).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that claim 11, which depends from claim 10 and adds a list of specific accelerator types, was obvious. Petitioner mapped elements of the ’459 patent to most of these limitations: the Huffman codec 260 was identified as the required "programmable entropy decoder," and the video processor 280 was argued to meet the limitations for an "inverse quantizer," "inverse transform accelerator," and "pixel filter." The petition argued that to the extent ’459 did not explicitly disclose a "motion compensator," this feature was rendered obvious by Fandrianto ’842, which taught a motion compensator (shifter units 140, 142) within its Motion Estimation Section.
    • Motivation to Combine: A POSITA would combine the references because they both addressed video decoding for videoconferencing and described functionally analogous systems. A POSITA reading ’459, which taught motion estimation, would have been motivated by ’842's teaching that motion compensation is a related and interchangeable technique for improving decoding. The motivation was to incorporate a known solution (motion compensation) from ’842 to solve a known problem (visual redundancy) in the similar system of ’459.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Motion compensation was a well-understood, predictable technique common in video decoding, and integrating this function into the ’459 architecture would predictably improve decoding performance without requiring undue experimentation.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 5 and 12 based on Fandrianto ’842 in view of Fandrianto ’459, arguing that ’459 supplied teachings on accelerators assisting a processor and the use of de-blocking filters.

4. Key Claim Construction Positions

  • Petitioner proposed that the term "accelerator" should be construed to mean "a device that speeds up or enhances operation." This construction was central to the petition, as it allowed various specialized hardware components described in the prior art—such as video processors, Huffman codecs, and DCT sections—to meet the "hardware accelerator" limitation of the challenged claims, thereby supporting the anticipation and obviousness grounds.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-14 of Patent 8,284,844 as unpatentable.