PTAB
IPR2018-01227
Amazon.com, Inc. v. Realtime Adaptive Streaming LLC
1. Case Identification
- Case #: IPR2018-01227
- Patent #: 9,578,298
- Filed: June 15, 2018
- Petitioner(s): Amazon.com, Inc., Hulu, LLC, and Netflix, Inc.
- Patent Owner(s): Realtime Adaptive Streaming LLC
- Challenged Claims: 1-19
2. Patent Overview
- Title: Method for processing a video stream of digital images.
- Brief Description: The ’298 patent discloses methods and systems for processing a stereoscopic (3D) digital video stream to extract a 2D-compatible video signal. The technology enables a single stereoscopic stream to be displayed in 2D on conventional devices by packing left and right images into a "composite frame" and then using metadata to selectively decode only one of those images for display.
3. Grounds for Unpatentability
Ground 1: Anticipation and Obviousness over Tian - Claims 1-13 and 15-19 are anticipated under 35 U.S.C. §102 or, alternatively, obvious under §103 over Tian.
- Prior Art Relied Upon: Tian (Patent 9,036,714).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Tian teaches all elements of the challenged claims. Tian was shown to disclose methods for processing video with multiple pictures combined into a single picture (a "composite frame") using various packing formats like side-by-side. Petitioner asserted Tian taught using Supplemental Enhancement Information (SEI) messages as metadata to signal how the pictures are combined, including their geometry and packing type. Crucially, Petitioner contended that Tian explicitly teaches the core inventive concept: decoding only a subset of the composite picture. Tian states its method can "provide a decoded representation of at least one of the multiple pictures" and that this selective decoding can be based on user input. For dependent claims, Tian was argued to disclose an "undivided" image in its side-by-side packing examples and using metadata coordinates to define the image area.
- Motivation to Combine (for §103 alternative): Petitioner argued that if any minor element were deemed missing from Tian for anticipation, a person of ordinary skill in the art (POSA) would have been motivated by Tian’s own disclosures to implement it. As Tian's stated objective was to facilitate the easy and convenient display of multi-view streams, any minor modifications to achieve the claimed system would have been obvious.
Ground 2: Obviousness over Lei and the 2010 H.264 Amendment - Claims 1-13 and 15-19 are obvious over Lei in view of the 2010 H.264 Amendment.
- Prior Art Relied Upon: Lei (Application # US 2005/0084006) and the 2010 H.264 Amendment (a JVT technical document).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Lei teaches the fundamental concept of the ’298 patent: combining stereoscopic images into a single frame and recognizing it would be "advantageous if only one view...could be decoded to permit viewing on legacy 2D displays." Lei taught using an SEI message to signal display capabilities and elect to decode only one of the interlaced fields if the display is non-3D. The 2010 H.264 Amendment was presented as providing the specific, standardized SEI message syntax (the "frame packing SEI message") that details the geometry and type of various frame packing arrangements (e.g., side-by-side, top-bottom).
- Motivation to Combine: A POSITA would combine Lei with the 2010 H.264 Amendment because both references address stereo-view video encoding and decoding. Lei expressly suggests using the H.264 standard, and the Amendment provides an updated, standardized syntax for it. The combination was framed as a simple substitution of a known element (Lei's more general SEI message concept) with a more specific, standardized, and improved element (the Amendment's detailed SEI message) to achieve the predictable results of improved compatibility and compression within the H.264 ecosystem.
- Expectation of Success: A POSITA would have a high expectation of success, as the combination involves implementing a published industry standard (H.264) to achieve its intended function.
Ground 3: Obviousness of Claim 14 over Tian and Shimada - Claim 14 is obvious over Tian in view of Shimada.
- Prior Art Relied Upon: Tian (Patent 9,036,714) and Shimada (Patent 4,866,542).
- Core Argument for this Ground:
- Prior Art Mapping: This ground specifically targeted claim 14, which recites that the decoding method is "activated by the user by pressing a specific remote control button." Petitioner asserted that Tian discloses activating the decoding method based on a general "user's command" or "user input." Shimada was cited for its disclosure of a conventional "remote-controlling commander" with push buttons for the manual operation of electronic devices.
- Motivation to Combine: A POSITA would combine these teachings as a matter of simple design choice. It would have been obvious to implement Tian's generic "user input" mechanism with the specific, convenient, and ubiquitous remote control taught by Shimada to improve the system's usability. This represents a predictable use of a known technique to improve a similar device.
- Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 14 based on the combination of Lei, the 2010 H.264 Amendment, and Shimada, relying on a similar motivation to add a known remote control for user convenience.
4. Key Claim Construction Positions
- Petitioner argued for specific constructions of key terms that were central to its invalidity arguments, contending they were consistent with the patent's specification and prosecution history.
- "composite frame": Petitioner proposed construing this term as "a frame containing a pair of stereoscopic images." This construction was argued as necessary to show that prior art references like Tian, which describe combining multiple pictures into a single frame, meet this claim limitation.
- "undivided": Petitioner proposed construing this term as "wholly contained within a determined area of the composite frame." This limitation was added during prosecution to distinguish prior art. Petitioner argued this construction is supported by the patent's own figures and that under this construction, common prior art packing formats (e.g., side-by-side) meet the limitation for dependent claim 2.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of Patent 9,578,298 as unpatentable.