PTAB

IPR2019-00806

Unified Patents Inc v. Velos Media LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Context Adaptive Binary Arithmetic Coding (CABAC)
  • Brief Description: The ’241 patent discloses methods and apparatuses for video data coding using CABAC. The purported invention centers on improving efficiency by using the same "context set" for entropy encoding and decoding both the Cb (blue difference) and Cr (red difference) chroma coded block flags.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 2 are obvious over Sasai in view of Kao.

  • Prior Art Relied Upon: Sasai (Application # 2013/0003861) and Kao (Application # 2009/0196355).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sasai, an application related to High Efficiency Video Coding (HEVC), teaches nearly all elements of independent claim 1. Sasai discloses a method of decoding video data using CABAC, including selecting a context for Cb and Cr chroma coded block flags (cbf_cb and cbf_cr) from a context set based on the "hierarchical depth" (i.e., transform depth) of a transform unit. Petitioner contended the key limitation of claim 1—using the same selected context for both the Cb and Cr flags—was rendered obvious by Sasai in view of Kao. While Sasai disclosed using the same context set (a plurality of contexts 0, 1, 2, 3) for both flags, Petitioner asserted Kao explicitly taught using the "same context" to decode consecutive bins of a data sequence in a CABAC system.
    • Motivation to Combine: A POSITA would combine the teachings of Sasai and Kao to achieve predictable improvements in video decoding efficiency and reduce memory usage, a recognized goal in the art. Petitioner argued that a POSITA implementing Sasai's system would be faced with a finite, predictable design choice: using the same context or different contexts for the Cb and Cr flags. Kao’s teaching provided the explicit suggestion to use the same context, making the combination a matter of applying a known technique to a known system to yield predictable results.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved routine software adjustments to Sasai’s decoder to implement a known decoding strategy from Kao. The limited number of options for context selection would have made the outcome of the combination predictable and successful for its intended purpose of improving decoding.

Ground 2: Claims 5, 6, and 9-13 are obvious over Sasai.

  • Prior Art Relied Upon: Sasai (Application # 2013/0003861).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sasai alone renders claims 5, 6, and 9-13 obvious. Independent claim 5 recites an apparatus (rather than a method) with a memory and a processor configured to perform the decoding steps. Petitioner asserted that Sasai expressly discloses various apparatuses, such as a cellular phone and a television, that include processors and memory and perform the claimed decoding techniques. Critically, Petitioner argued that Sasai’s disclosure of using the same context set for both the Cb and Cr flags meets the central limitation of claim 5.
    • Dependent Claim Mapping: Petitioner further contended that Sasai discloses the limitations of the dependent claims. Claim 6 (decoding non-zero transform coefficients) is met by Sasai’s disclosure of decoding transform coefficients when the cbf_cb and cbf_cr flags are non-zero. Claim 9 (adding a display device) is met by Sasai’s description of cellular phones and televisions with display units. Claim 10 (listing device types like a smartphone or television) is met by Sasai’s explicit examples of such devices. Claims 11-13, which recite a method for encoding that mirrors the decoding claims, were argued to be obvious for the same reasons based on Sasai's disclosure of a corresponding encoder.

4. Key Claim Construction Positions

  • Petitioner submitted that none of the claim terms required explicit construction. The terms were argued to carry their plain and customary meaning as understood by a person of ordinary skill in the art of video coding.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 5, 6, and 9-13 of the ’241 patent as unpatentable under 35 U.S.C. §103.