Apple Inc v. Redcom LLC

1. Case Identification

• Case #: IPR2019-01065
• Patent #: 9,245,314
• Filed: May 6, 2019
• Petitioner(s): Apple Inc.
• Patent Owner(s): Redcom, LLC
• Challenged Claims: 1-30

2. Patent Overview

• Title: Video Camera
• Brief Description: The ’314 patent is directed to a video camera configured to capture, compress, and store high-resolution raw video image data in a memory device. The system includes an image sensor, an image processing module, and a compression module.

3. Grounds for Unpatentability

Ground 1: Obviousness over Presler and Molgaard - Claims 1-10, 12-13, 15-26, and 28-29 are obvious over Presler in view of Molgaard.

• Prior Art Relied Upon: Presler (Patent 9,565,419) and Molgaard (Patent 7,656,561).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Presler disclosed a portable, high-definition digital camera system capable of capturing raw images at various video rates (e.g., 2K and 4K). This system included an image sensor, a frame grabber, a modular processing subsystem with reprogrammable software, and removable storage, satisfying the core structural elements of the challenged claims. However, Presler’s primary compression method was wavelet-based. Petitioner asserted that Molgaard supplemented Presler by teaching methods for lossless, near-lossless, and lossy compression specifically optimized for raw image data from a sensor with a Bayer filter pattern, which is a type of "raw mosaiced image data." Molgaard’s teaching of processing raw mosaiced data (e.g., through "black calibration") to produce processed data with a single data value per pixel, and then compressing that processed data using a mathematically lossy technique to achieve a visually lossless result, allegedly rendered the claimed processing and compression steps obvious.
  • Motivation to Combine: A POSITA would combine Molgaard’s efficient compression techniques with Presler’s camera system to improve performance. Molgaard’s methods, such as gamma correction and bit-reduction, reduce the amount of data required, allowing for faster compression and the use of less expensive hardware than Presler’s methods alone. This combination would achieve a superior compression ratio and image quality, providing a strong motivation for a skilled artisan to integrate Molgaard’s teachings into the Presler system.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references because both relate to digital video cameras processing raw image data. Integrating Molgaard’s compression algorithms, which could be implemented in software, into Presler’s reprogrammable software-based processing system would be a straightforward application of known principles.

Ground 2: Obviousness over Presler, Molgaard, and Sodini - Claims 11 and 27 are obvious over Presler in view of Molgaard, further in view of Sodini.

• Prior Art Relied Upon: Presler (’419 patent), Molgaard (’561 patent), and Sodini (Patent 7,349,574).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Presler and Molgaard. Petitioner argued that claims 11 and 27 require processing raw mosaiced image data with a "pre-emphasis function" that increases data values for dark regions and decreases them for bright regions. Sodini allegedly disclosed this feature by teaching a "smoothing filter" for processing non-linear image data from a digital imager. This filter works by "clamping" pixel values that are outside a predetermined range (i.e., too bright or too dark) relative to neighboring pixels, which Petitioner contended is equivalent to the claimed pre-emphasis function.
  • Motivation to Combine: A POSITA would be motivated to add Sodini's teachings to the Presler/Molgaard combination to improve image quality. Molgaard’s methods seek to remove "fixed pattern noise," and Sodini's smoothing filter would enhance this capability by removing blemishes and single-pixel defects (e.g., from pixel failure in the sensor) by clamping outlier pixel values. This would result in a cleaner image before compression.

Ground 3: Obviousness over Presler, Molgaard, and Frost - Claims 14 and 30 are obvious over Presler in view of Molgaard, further in view of Frost.

• Prior Art Relied Upon: Presler (’419 patent), Molgaard (’561 patent), and Frost (Patent 8,170,402).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground also built upon the Presler/Molgaard combination. Petitioner argued that claims 14 and 30 require a memory device sufficiently large to store at least 30 minutes of video at 12-megapixel resolution, 12-bit color, and 60 frames per second, which Petitioner calculated to be at least 324 gigabytes. Frost allegedly disclosed a portable storage device compatible with high-definition cameras that met this limitation. Frost’s device has a minimum capacity of 512 gigabytes, comprising multiple memory boards and modules.
  • Motivation to Combine: A POSITA would be motivated to use a storage device like that taught by Frost with the Presler camera system to satisfy the large storage requirements for high-resolution video data. Frost explicitly teaches a portable, robust storage solution designed for professional video cameras, making it a suitable and obvious choice for the high-data-rate applications described in Presler.

4. Key Claim Construction Positions

• "Raw Mosaiced Image Data": Petitioner argued this term should be construed to mean "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 using color filter arrays (e.g., Bayer filters) before demosaicing.
• "Substantially Visually Lossless": Relying on the patent’s intrinsic definition of "visually lossless," Petitioner proposed this term means "sets of data that are substantially visually similar from the point of view of one of ordinary skill in the art."
• Memory Capacity (Claims 14 and 30): Petitioner argued that the limitation "sufficiently large to store... at least about 30 minutes of video" requires a capacity of at least 324 gigabytes. This was calculated based on the specified video parameters (12MP, 12-bit, 60fps) and the minimum 6:1 compression ratio disclosed in the patent’s specification.

5. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner dedicated significant argument to contending that the ’314 patent was not entitled to the April 11, 2007, filing date of its earliest provisional application. Petitioner argued the provisional application lacked written description support for the key limitation of outputting raw mosaiced image data at a resolution of at least 2k and a frame rate of at least 23 frames per second. This argument was critical for establishing that Presler, which claims priority to an April 13, 2007, application, qualifies as prior art.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-30 of the ’314 patent as unpatentable.