PTAB

IPR2018-01189

Hulu, LLC v. Realtime Adaptive Streaming LLC

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1. Case Identification

2. Patent Overview

  • Title: Method and Device for Coding a Video Signal
  • Brief Description: The ’777 patent relates to methods and systems for digital video encoding and decoding. The purported novelty rests on a process for improving compression efficiency by calculating two quantization efficiencies for a block of video data—one with the original quantized values and one with those values set to zero—and then selecting the version with the higher efficiency for further processing.

3. Grounds for Unpatentability

Ground 1: Obviousness over Winger and Keesman - Claims 1-8, 11-12, and 14 are obvious over Winger in view of Keesman under 35 U.S.C. §103.

  • Prior Art Relied Upon: Winger (Application # 2004/0240556) and Keesman (Patent 5,691,770).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Winger taught a conventional hybrid video coding system that improves rate-distortion performance through "coefficient cancellation." Winger’s method involved approximating quantization efficiency by comparing a sum of absolute values (SAV) for a block of coefficients against a predetermined threshold to decide whether to set the block to zero. Keesman, addressing the same problem of balancing bitrate and distortion, taught a more sophisticated and direct method for this decision. Keesman explicitly disclosed calculating and comparing two "Lagrangian costs" (a specific type of cost function balancing rate and distortion) for video data: one for the original quantized coefficients and a second for the case where those coefficients are set to zero. The outcome with the lower cost (higher efficiency) is then selected. Petitioner contended that combining Winger’s general coding framework with Keesman’s specific cost-comparison method renders the claims obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Winger and Keesman because both references address the same problem of improving video compression by selectively zeroing coefficients. Winger expressly suggested that "other block-based measurements" beyond its disclosed SAV technique could be used to meet specific design criteria. Keesman provided a well-known and superior rate-distortion measurement technique (the Lagrangian cost function) that a POSITA would have been motivated to substitute into Winger's system to achieve a better trade-off between implementation complexity and estimation accuracy, which Winger identified as a disadvantage of existing techniques.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination represented a simple substitution of one known measurement technique (Winger's SAV) with another known, more precise technique (Keesman's Lagrangian cost) to perform the same function within a conventional video encoder. The result would be a predictable improvement in compression performance.

Ground 2: Obviousness over Winger, Keesman, and Sugiyama - Claims 9 and 10 are obvious over Winger, Keesman, and Sugiyama under §103.

  • Prior Art Relied Upon: Winger (Application # 2004/0240556), Keesman (Patent 5,691,770), and Sugiyama (Patent 5,850,259).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to address claims 9 and 10, which recite a method for decoding a video signal that was coded according to the method of claim 1. While the combination of Winger and Keesman taught the claimed encoding method, Winger only briefly mentioned a decoder without providing structural detail. Sugiyama was introduced because it taught a standard decoding apparatus with the necessary components (e.g., variable length decoder, inverse quantizer, inverse DCT) to decode a video stream produced by an encoder like the one described in the Winger/Keesman combination. Sugiyama’s decoder was designed to accept coded video data and effectively reproduce the video signal.
    • Motivation to Combine: A POSITA, having developed the encoder taught by the combination of Winger and Keesman, would be motivated to create a complete, functioning end-to-end video processing system, which requires a compatible decoder. Since Winger’s decoder was not detailed, a POSITA would naturally look to a reference like Sugiyama, which disclosed a conventional decoder architecture designed to be compatible with standard encoders. The motivation was to pair the known encoder with a known decoder to create a fully functional system.
    • Expectation of Success: A POSITA would have a high expectation of success because combining the Winger/Keesman encoder with the Sugiyama decoder involved pairing compatible, well-understood components. The result would be a predictable, fully functioning encoding and decoding system.

4. Key Claim Construction Positions

  • "means for reducing temporal redundancy" (Claim 11): Petitioner argued this is a means-plus-function term. Based on the prosecution history, where the Patent Owner and Examiner agreed on the structure, Petitioner asserted the function is "reducing temporal redundancy" and the corresponding structure is the "adder/subtractor" that receives an input signal and a prediction signal, as depicted in the patent’s figures.
  • "control means for..." (Claim 11): Petitioner argued this is a means-plus-function term with a five-part function corresponding to the core steps of the invention (calculating a first efficiency, setting values to zero, calculating a second efficiency, and selecting the outcome). Petitioner contended the corresponding structure, as identified by the Examiner during prosecution, is "an encoder along with the algorithm disclosed in figure 3" of the ’777 patent.

5. Relief Requested

  • Petitioner requested that inter partes review of the ’777 patent be instituted and that Claims 1-12 and 14 be canceled as unpatentable.