PTAB

IPR2019-01064

Apple Inc v. Redcom LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Video Camera
  • Brief Description: The ’299 patent relates to a video camera configured to capture, compress, and store video image data in a memory of the camera, particularly focusing on processing raw image data.

3. Grounds for Unpatentability

Ground 1: Claims 1-9, 11-12, 14-24, 26-27, and 29 are obvious over Presler, Molgaard, and Chui.

  • Prior Art Relied Upon: Presler (Patent 9,565,419), Molgaard (Patent 7,656,561), and Chui (Patent 5,600,373).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Presler disclosed the core video camera system, including a portable housing, an image sensor, electronics with an image processing module, a compression module, and a memory device. Presler taught a portable digital camera for recording high-definition raw images (2K, 4K) with a modular processing subsystem. However, Presler did not explicitly detail compressing raw mosaiced data. Molgaard was argued to supply this element, as it taught lossless and near-lossless compression specifically optimized for raw image data from a sensor with a Bayer filter pattern, which Petitioner equated with the claimed "raw mosaiced image data." For the claimed Huffman compression technique, Petitioner asserted that Chui taught various lossless compression techniques, including Huffman encoding, for video data.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Presler and Molgaard because Molgaard’s optimized compression for raw Bayer-filter data would be a desirable and logical improvement for Presler’s raw-image-capturing camera. A POSITA would have been further motivated to incorporate Chui’s Huffman encoding into the lossless compression stage taught by Molgaard because it was a well-known, conventional, and desirable technique, making it a simple substitution of one known lossless method for another to achieve a predictable result.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references, as implementing a known compression algorithm like Huffman encoding (Chui) within a system designed for raw data compression (Molgaard) in a high-resolution digital camera (Presler) was well within the ordinary skill in the art.

Ground 2: Claims 10 and 25 are obvious over Presler, Molgaard, and Chui, further in view of Sodini.

  • Prior Art Relied Upon: Presler (Patent 9,565,419), Molgaard (Patent 7,656,561), Chui (Patent 5,600,373), and Sodini (Patent 7,349,574).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Presler, Molgaard, and Chui and added Sodini to teach the limitations of claims 10 and 25, which required processing raw mosaiced data with a "pre-emphasis function." Petitioner argued that Sodini disclosed a method for processing non-linear image data from a digital imager using a "smoothing filter" to eliminate single-pixel defects. This filter worked by clamping pixel values that exceeded a maximum or minimum value relative to neighboring pixels. Petitioner contended that this clamping function met the claim limitation, as clamping high values decreased data for bright regions and clamping low values increased data for dark regions.
    • Motivation to Combine: A POSITA would combine Sodini with the primary combination because Molgaard’s image processing sought to remove "fixed pattern noise" and other blemishes from Bayer image data. Sodini’s smoothing filter offered a known technique to improve the removal of such sensor-induced defects, making it an obvious addition to enhance the image processing capabilities of the combined Presler/Molgaard system.

Ground 3: Claims 13 and 28 are obvious over Presler, Molgaard, and Chui, further in view of Frost.

  • Prior Art Relied Upon: Presler (Patent 9,565,419), Molgaard (Patent 7,656,561), Chui (Patent 5,600,373), and Frost (Patent 8,170,402).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Frost to the primary combination to teach the limitations of claims 13 and 28, which required a memory device "sufficiently large" to store about 30 minutes of 12-megapixel, 12-bit color video at 60 frames per second. Petitioner calculated this required approximately 324 gigabytes of storage. Frost disclosed a portable, high-capacity storage device compatible with high-definition digital video cameras. Specifically, Frost’s device had a minimum capacity of 512 gigabytes, which satisfied the claimed storage requirement.
    • Motivation to Combine: A POSITA would combine Frost with the primary combination because Presler’s camera was designed for high-resolution video and used an external storage device. Frost’s high-capacity, portable, and compatible storage device was exactly the type of component a POSITA would select to meet the significant storage demands of the high-resolution video formats captured by Presler’s camera.

4. Key Claim Construction Positions

  • "Raw Mosaiced Image Data": Petitioner argued this term should be understood to include "motion video image data directly from a camera's image sensor, where each pixel represents one color." This construction was based on extrinsic evidence describing raw data from sensors with Bayer filters.
  • "Demosaiced Motion Video Data": Petitioner proposed this term means "full-color motion video data reconstructed from mosaiced motion video data." This construction was based on the patent’s discussion of outputting full-color RGB or YCC format video.
  • "Substantially Visually Lossless": Based on the patent’s explicit definition, Petitioner argued this meant "sets of data that are substantially visually similar from the point of view of one of ordinary skill in the art."
  • "the memory device is sufficiently large...": Petitioner contended this functional language required a specific capacity, calculating that a memory device meeting the specified performance parameters would need a total capacity of at least 324 gigabytes.

5. Key Technical Contentions (Beyond Claim Construction)

  • Effective Filing Date: Petitioner dedicated significant argument to establishing that the ’299 patent was not entitled to the benefit of its earliest provisional application’s filing date (April 11, 2007). Petitioner argued the provisional application lacked written description support for key limitations recited in the independent claims, such as outputting raw mosaiced image data "at a resolution of at least 2k and at a frame rate of at least about 23 frames per second." This contention was critical because it established Presler, which claimed priority to an April 13, 2007 application, as prior art to the ’299 patent.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-29 of the ’299 patent as unpatentable.