PTAB

IPR2018-01734

Samsung Electronics Co., Ltd. v. VISUAL EFFECT INNOVATIONS, LLC

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1. Case Identification

2. Patent Overview

  • Title: Method for Generating and Displaying Modified Video
  • Brief Description: The ’874 patent relates to methods for generating and displaying modified video with 3-dimensional effects. The challenged claim recites a method of generating two different "altered image frames" by acquiring a source video, modifying an image frame from it, and then generating the altered frames from selected, non-overlapping portions of the modified frame.

3. Grounds for Unpatentability

Ground 1: Claim 1 is anticipated under 35 U.S.C. §102 by Seong.

  • Prior Art Relied Upon: Seong (Application # 2011/0279450A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seong, which discloses a 3D image-display apparatus, teaches every element of claim 1. Seong describes a method where a 3D image is processed into left-eye and right-eye images, which are displayed alternately, potentially with a black image displayed between them. Petitioner contended that Seong's process of displaying partial images (e.g., a top-half image with a bottom-half black frame) directly corresponds to the ’874 patent's "first altered image frame" which includes "first and second non-overlapping portions." Similarly, Petitioner mapped another of Seong's display configurations (e.g., a bottom-half image with a top-half black frame) to the claimed "second altered image frame," which includes different "third and fourth non-overlapping portions." Seong's disclosure of video scaling was mapped to the "expanding the first image frame" limitation.
    • Key Aspects: A critical predicate for this ground is Petitioner's assertion that claim 1 of the ’874 patent is not entitled to a priority date earlier than July 16, 2014. Petitioner argued that the specific limitations regarding the creation of the two distinct altered image frames from non-overlapping portions (elements 4 and 5 of claim 1) constituted new matter first introduced in the application filed on that date. This effective filing date makes Seong, published in 2011, valid prior art under §102.

Ground 2: Claim 1 is obvious under 35 U.S.C. §103 over Takahara in view of either MacInnis or Hirano.

  • Prior Art Relied Upon: Takahara (Patent 6,628,355), MacInnis (Patent 6,853,385), and Hirano (Patent 6,144,412).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Takahara discloses most elements of claim 1. Takahara describes an LCD panel circuit that improves dynamic image quality by alternately displaying a natural image and a black frame. It explicitly teaches displaying images using a "raster display" method where lines from the natural image are alternated with lines from the black frame. Petitioner argued this process creates the "first and second altered image frames" with their respective non-overlapping portions as claimed. However, Takahara does not expressly disclose "expanding the first image frame" to generate a "modified image frame." This missing element, Petitioner argued, is supplied by either MacInnis or Hirano, both of which teach video scalers for upscaling (i.e., expanding) images to fit different display formats.
    • Motivation to Combine: A POSITA would combine Takahara with MacInnis or Hirano due to market demands and industry standards. Specifically, the Advanced Television Systems Committee (ATSC) standard required televisions to be capable of upscaling video signals to display HDTV content. A POSITA seeking to implement Takahara’s display technology would have been motivated to incorporate a known upscaling solution like that in MacInnis or Hirano to create a commercially viable product compliant with the ATSC standard.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination because it involved applying a conventional video scaling technique (from MacInnis or Hirano) to a known video display method (from Takahara) to achieve the predictable result of a display capable of both high-quality dynamic motion and standards-compliant image sizing.

4. Key Claim Construction Positions

  • Petitioner argued that the terms of the challenged claim should be given their ordinary and customary meaning under the broadest reasonable interpretation standard.
  • A central term highlighted was "expanding the first image frame." Petitioner noted that in related district court litigation, the Patent Owner asserted this limitation is met by the well-known process of "upscaling" an image's resolution to fit a screen. Petitioner adopted this position for its obviousness argument, directly linking the function of the scalers in MacInnis and Hirano to the language of the claim.

5. Key Technical Contentions (Beyond Claim Construction)

  • The petition's primary technical contention, which formed the foundation for Ground 1, was that claim 1 of the ’874 patent is not entitled to its claimed priority date of 2001.
  • Petitioner dedicated a substantial portion of the petition to a detailed analysis of the patent’s priority chain, arguing that the specific, elaborate conditions for generating the "first altered image frame" and "second altered image frame" (claim elements 4 and 5) were absent from all parent applications until new matter was introduced in the application filed on July 16, 2014. Therefore, any reference published before this 2014 date, including Seong (2011), qualifies as prior art against claim 1.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 1 of the ’874 patent as unpatentable.