PTAB

IPR2019-00725

Unified Patents LLC v. KoReaN Broadcasting System

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Video Encoding and Decoding Method Using Hierarchical Block Partitioning
  • Brief Description: The ’720 patent describes methods for encoding and decoding digital video by hierarchically partitioning a macroblock into sub-blocks. The invention centers on transforming these sub-blocks using multiple transform kernels of different sizes within the same macroblock to improve compression efficiency.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 are anticipated by Winken under §102 or, alternatively, obvious over Winken in view of Kim under §103.

  • Prior Art Relied Upon: Winken (Application # 2013/0034171) and Kim (Application # 2012/0128070).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Winken teaches every limitation of the challenged claims. Winken discloses a method for video decoding that involves dividing a slice into coding blocks ("treeblocks"), which are analogous to the claimed "decoding unit blocks." Winken explicitly teaches subdividing a treeblock into four sub-blocks and further subdividing at least one of those into four smaller sub-blocks, mapping to the claimed hierarchical structure. Crucially, Petitioner asserted that Winken discloses transforming these sub-blocks using multiple transform blocks of varying sizes (e.g., quadratic or rectangular), which a POSITA would understand requires corresponding transform kernels of different sizes. This meets the key claim limitation of applying, for example, a "first transform kernel" and a "second transform kernel having a different size." The same logic applies to both the divided and undivided sub-blocks as claimed.
    • Motivation to Combine (for §103 grounds): Petitioner argued that in the event any limitation was found missing from Winken, a POSITA would combine it with Kim. Both references are in the same field of digital video coding, share the goal of improving H.264 efficiency, and use identical underlying techniques like block partitioning and transformation. Kim, which is effectively the parent application of the ’720 patent, provides any allegedly missing details, making the combination a simple application of known techniques to achieve predictable results.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success because the combination involves applying known mathematical concepts that were already successfully implemented in the H.264 video coding standard.

Ground 2: Claims 1-6 are anticipated by JCTVC-R1013 under §102 or, alternatively, obvious over JCTVC-R1013 in view of Kim under §103.

  • Prior Art Relied Upon: JCTVC-R1013 ("Draft high efficiency video coding (HEVC) version 2...") and Kim (Application # 2012/0128070).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that JCTVC-R1013, a draft of the HEVC standard, discloses all claimed elements. It describes a "coding tree block" that is recursively partitioned using a quadtree structure, which directly corresponds to the claimed method of dividing a decoding unit block into four first sub-blocks and further dividing at least one of those into four second sub-blocks. Petitioner highlighted that JCTVC-R1013 teaches that each coding block is the root of both a prediction tree and a transform tree. This structure explicitly allows a single sub-block (e.g., 16x16) to be transformed using kernels of different sizes (e.g., one 8x8 kernel and four 4x4 kernels), directly mapping to the claim limitations requiring transform kernels of different sizes for both divided and undivided sub-blocks.
    • Motivation to Combine (for §103 grounds): The motivation to combine JCTVC-R1013 with Kim was argued to be the same as for the Winken combination. Both references address improving video compression efficiency using the same fundamental, predictable techniques.
    • Expectation of Success (for §103 grounds): Success was expected because the combination would simply apply the well-understood and predictable principles of block-based video compression detailed in both references.

4. Key Technical Contentions

  • Priority Date Challenge: A central argument of the petition was that the ’720 patent is not entitled to the February 23, 2010 priority date of its parent, the ’512 patent. Petitioner argued the ’512 patent specification lacks written description support for the key limitation of using transform kernels of different sizes on a single macroblock. According to Petitioner, the ’512 patent only discloses dividing macroblocks into uniform sub-blocks that are all transformed using a single, same-sized kernel. Because this limitation was allegedly introduced without support, the ’720 patent’s effective filing date is its actual filing date of September 7, 2016. This makes Winken, Kim, and JCTVC-R1013, all published between 2012 and 2014, valid prior art references.

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-6 of the ’720 patent as unpatentable.