PTAB

IPR2018-00697

Samsung Electronics Co Ltd v. M & K Holdings Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Intracoding in Video Encoding
  • Brief Description: The ’673 patent discloses a video encoding method involving intra prediction processes. The method involves generating a prediction block, creating a residual block, and then transforming, quantizing, and entropy-coding the residual block, with specific rules for scanning transform coefficients based on block size and prediction modes.

3. Grounds for Unpatentability

Ground 1: Obviousness over Budagavi and Sole - Claims 1-3 are obvious over Budagavi in view of Sole.

  • Prior Art Relied Upon: Budagavi (Application # 2011-0170594) and Sole (JCTVC-E335, a contribution to the HEVC video coding standard).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Budagavi taught a complete video encoding method, including determining an intra prediction mode, generating a prediction block, transforming and quantizing a residual block, and entropy-coding the resulting coefficients. However, Budagavi was allegedly vague regarding the specific scanning process for the quantized coefficients. Sole was argued to supply the missing elements, specifically teaching that for larger blocks (like 8x8), the block of coefficients should be divided into a plurality of smaller subsets (e.g., 4x4 sub-blocks) and that both the subsets and the coefficients within them should be scanned according to a scan pattern (e.g., zigzag) determined by the intra prediction mode. The combination of Budagavi's framework and Sole's specific scanning technique allegedly rendered independent claim 1 obvious. Dependent claims 2 and 3, which specify scanning the subsets and coefficients in a reverse direction, were also allegedly disclosed by Sole’s teaching of backward scan patterns.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) implementing Budagavi's method would be motivated to improve its underspecified scanning component. Petitioner contended that a POSITA would look to known, efficient scanning techniques from the relevant field, such as those in developing standards like HEVC, which is the subject of Sole. Budagavi itself referenced a proposal to the same HEVC working group, suggesting a POSITA would consult such documents.
    • Expectation of Success: A POSITA would expect success in combining the references because implementing Sole’s advanced scanning method within Budagavi’s general encoding framework was a predictable application of known techniques to improve scanning efficiency, a well-understood goal in video compression.

Ground 2: Obviousness over Budagavi, Sole, and WD3-v1 - Claims 4-7 are obvious over Budagavi and Sole in view of WD3-v1.

  • Prior Art Relied Upon: Budagavi (Application # 2011-0170594), Sole (JCTVC-E335), and WD3-v1 (JCTVC-E603, a working draft of the HEVC standard).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Budagavi and Sole from Ground 1, adding WD3-v1 to teach the limitations of dependent claims 4-7. Petitioner argued WD3-v1, as a detailed HEVC standard draft, provided specific rules for handling common scenarios in intra prediction. For claim 4, WD3-v1 taught coding the intra prediction mode based on neighboring (upper and left) blocks and, critically, setting the mode to a default DC mode if a neighboring prediction mode is unavailable. For claims 5 and 6, WD3-v1 specified a direct mapping between the intra prediction mode and the scan pattern, disclosing that a vertical prediction mode uses a horizontal scan and a horizontal prediction mode uses a vertical scan. For claim 7, WD3-v1 described processes for generating new reference pixels when the required neighboring pixels are unavailable (e.g., at a frame border).
    • Motivation to Combine: A POSITA enhancing the Budagavi-Sole method would be motivated to incorporate the robust, standardized solutions from WD3-v1 to handle predictable edge cases. Since Budagavi and Sole operate in the HEVC context, consulting a primary HEVC working draft like WD3-v1 to refine the encoding logic for issues like unavailable predictors or optimizing scan patterns was presented as a natural and logical step.
    • Expectation of Success: The combination was allegedly predictable. Integrating the specific, standardized rules from WD3-v1 into the more general Budagavi-Sole framework would predictably result in a more efficient and robust encoder without requiring undue experimentation.

4. Key Claim Construction Positions

  • Petitioner argued that terms reciting functional units (e.g., “transform/quantization unit,” “intra predictor”) should not be construed as means-plus-function terms under §112, 6th paragraph.
  • This position was based on prosecution history estoppel. The Petitioner asserted that during prosecution, the Examiner raised indefiniteness issues with the original apparatus claims, which were then amended into the current method claims, deleting phrases like "configured to." Petitioner argued this was a clear disavowal of any means-plus-function interpretation to overcome the rejection and secure allowance of the claims.

5. Key Technical Contentions (Beyond Claim Construction)

  • A significant portion of the petition was dedicated to establishing that the technical documents Sole and WD3-v1 (and another reference, Zheng) qualify as "printed publications" and are therefore valid prior art.
  • Petitioner contended these documents were publicly accessible before the critical date of the ’673 patent. The argument was that they were uploaded to the Joint Collaborative Team on Video Coding (JCT-VC) document management site, which was publicly accessible without restriction, and also mirrored on the MPEG site. While the MPEG site required credentials, Petitioner provided evidence that these credentials were widely distributed to hundreds of members and interested parties, rendering the documents de facto public.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-7 of Patent 9,191,673 as unpatentable.