PTAB

IPR2018-00786

Vizio Inc v. Broadcom Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: MULTISTANDARD VIDEO DECODER
  • Brief Description: The ’059 patent discloses a multi-standard video decoder system designed to process encoded video streams. The system operates by identifying an "identifier" within received packetized data, which defines the specific encoding standard (e.g., MPEG-2, H.264) used for that data, and then selecting the appropriate decoding process from a plurality of available processes to decode the video.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chu - Claims 11, 12, and 19 are obvious over `Chu`.

  • Prior Art Relied Upon: `Chu` (Patent 7,167,108).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chu teaches all limitations of independent claim 11. Chu discloses a multi-standard decoder (Apparatus 300), which a person of ordinary skill in the art (POSITA) would understand could be implemented on a chip. This apparatus receives a "Formatted Data Stream" (the claimed "packetized data"), uses "Format Detectors" to determine a "Format Indicator" (the claimed "identifier") to identify the encoding standard, employs "Logic" to select a corresponding decoder from a plurality of available decoders, and then decodes the video data. Petitioner contended this maps directly to the receiving, determining, selecting, and decoding steps of claim 11. For dependent claim 12, Chu’s disclosure of using a "Start Code" to indicate the beginning of a frame was argued to meet the limitation of a start code that separates packets. For dependent claim 19, Petitioner asserted that Chu’s conversion of decoded data into a "Presentation Form" for a display device teaches the generation of a "decoded video stream."
    • Expectation of Success: While Chu does not explicitly disclose storing its software on a computer-readable medium, Petitioner argued it was a well-known and widely-used practice. A POSITA would have had a reasonable expectation of success in implementing such storage for Chu's decoder.

Ground 2: Obviousness over Chu and Watkinson - Claims 13, 14, 17, and 18 are obvious over `Chu` in view of `Watkinson`.

  • Prior Art Relied Upon: Chu (Patent 7,167,108) and `Watkinson` (The MPEG Handbook, 2001).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that while Chu teaches a multi-standard decoder capable of processing MPEG-2 streams, it does not disclose specific implementation details of the MPEG-2 standard that are recited in the dependent claims. Watkinson, a handbook on the MPEG standard, was argued to supply these missing details. For claims 13 and 14, Watkinson teaches that MPEG-2 decoding involves identifying ("matching") and then removing ("destuffing") "Stuffing Bytes" that are represented by a pre-determined byte sequence. For claim 17, Watkinson teaches that MPEG-2 decoding utilizes both Fixed Length Coding (FLC) and Variable Length Coding (VLC) processes. For claim 18, Watkinson discloses that decoded MPEG-2 data inherently comprises prediction pixel and prediction error information.
    • Motivation to Combine: A POSITA would combine Chu and Watkinson to implement the full, known features of the MPEG-2 standard into Chu's adaptable decoder architecture. Petitioner pointed out that Chu itself states its invention has the advantage of being adaptable as video standards proliferate, providing an express motivation to incorporate well-known standard-specific features like those in Watkinson.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination, as it involved applying a known technique (MPEG-2 decoding details from Watkinson) to a known, adaptable decoder (Chu) to achieve the predictable result of a fully compliant MPEG-2 decoding capability.

Ground 3: Obviousness over Kovacevic - Claims 11, 12, and 19 are obvious over `Kovacevic`.

  • Prior Art Relied Upon: `Kovacevic` (Application # 2005/0060420).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Kovacevic discloses a multimedia system that meets all limitations of claim 11. The system's Transport Stream Demultiplexor, implementable on a chip, receives packetized data and determines the encoding type (MPEG-1 or MPEG-2) by checking the value of an identifier called "Next Byte." Based on this identifier, the system selects one of two decoding processes (parsing MPEG-1 or MPEG-2 header data) and then decodes the payload data. Petitioner contended that for claim 12, Kovacevic’s search for a "Packet_Start_Code" teaches the claimed start code. For claim 19, Kovacevic’s routing of decoded payload data to a display device was argued to teach the generation of a decoded video stream.
    • Expectation of Success: Similar to the arguments for Chu, Petitioner argued it would have been obvious to a POSITA to store Kovacevic's "Microcode" on a computer-readable storage medium to allow its microprocessor to execute the instructions, as this was a standard and necessary practice for such systems.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Chu with `Richardson` (for H.264 features) and admitted prior art (for VC-1 features). Petitioner also asserted parallel grounds using Kovacevic as the primary reference in combination with Watkinson, Richardson, and admitted prior art to challenge the same sets of claims.

4. Relief Requested

  • Petitioner requests institution of inter partes review (IPR) and cancellation of claims 11-20 as unpatentable.