PTAB

IPR2018-01734

Samsung Electronics Co Ltd v. Visual Effect Innovations LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Generating and Displaying Modified Video
  • Brief Description: The ’874 patent discloses a method for generating and displaying modified video with three-dimensional effects. The claimed method involves acquiring a source video, modifying an image frame, and then generating two different "altered" image frames that each combine selected portions of the modified frame with other non-overlapping portions.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Seong (Application # 2011/0279450).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seong, which discloses a method for displaying 3D images, teaches every limitation of claim 1. Seong’s method involves receiving a 3D image, processing it into left-eye and right-eye images, and displaying them alternately, often with a black image displayed between them to improve quality. Petitioner mapped the claim limitations to Seong’s process where a "first altered image frame" corresponds to displaying the top half of a left-eye image with a black bottom half, and a "second altered image frame" corresponds to displaying the bottom half of the image with a black top half. This process inherently creates the non-overlapping portions required by the claim. Petitioner also contended that Seong's disclosure of video scaling meets the "expanding the first image frame" limitation.
    • Key Aspects: A threshold argument for this ground was that the ’874 patent is not entitled to its claimed 2001 priority date. Petitioner asserted the correct priority date is July 16, 2014, which is the filing date of the application that first disclosed the subject matter of challenged claim 1. This later priority date makes Seong, published in 2011, valid prior art against the ’874 patent.

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

  • 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 argued that Takahara discloses most elements of claim 1. Takahara teaches a method for improving LCD response time by alternately displaying a natural image and a black frame, which can be done on a line-by-line basis. This creates the "first and second altered image frames" comprising different non-overlapping portions of the natural image and the black frame. However, Takahara does not explicitly disclose the limitation of "expanding the first image frame." Petitioner asserted that MacInnis and Hirano both remedy this deficiency by expressly teaching video scaling (upscaling) circuits and methods for processing digital video signals to meet various display formats.
    • Motivation to Combine: A POSITA would combine Takahara with either MacInnis or Hirano due to market and technical demands. Specifically, Takahara's LCD panel technology would have needed to comply with the Advanced Television Systems Committee (ATSC) Digital Television Standard to display high-definition content. The ATSC standard required the upscaling capabilities taught by MacInnis and Hirano. Therefore, a POSITA would have been motivated to integrate the known scaling technology of MacInnis or Hirano into Takahara’s display method to create a commercially viable product that met industry standards.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Integrating video scalers into display systems was a well-known and conventional practice at the time, and both Takahara's display method and the scaling circuits of MacInnis and Hirano operated on standard video signals, making their combination predictable.

4. Key Claim Construction Positions

  • "expanding the first image frame": While Petitioner asserted that no terms required formal construction, it noted that Patent Owner argued in related district court litigation that this term is met by the process of "upscaling" an image to match screen resolution. Petitioner adopted this interpretation for its invalidity arguments, contending that the prior art discloses such upscaling.

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date of the ’874 Patent: A central contention of the petition was that claim 1 is not entitled to an effective filing date earlier than July 16, 2014. Petitioner argued that the specific limitations related to generating first and second altered image frames with non-overlapping portions constituted new matter first introduced in the application filed on that date. This argument was critical to establishing Seong (2011) as valid prior art for the anticipation ground.

6. Relief Requested

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