PTAB

IPR2019-01248

Google LLC v. Virentem Ventures LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of presenting an audio-visual work
  • Brief Description: The ’380 patent relates to a method for presenting an audio-visual work where the presentation rate is modified based on detected content properties. The system analyzes the work, particularly surveillance video, to detect properties like the presence of individuals, and adjusts the playback speed accordingly, for instance, by increasing the rate during periods with no individuals to allow for faster review.

3. Grounds for Unpatentability

Ground 1: Claim 1 is obvious over Mauldin in view of Bhadkamkar.

  • Prior Art Relied Upon: Mauldin (Patent 5,664,227) and Bhadkamkar (Patent 5,893,062).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mauldin discloses a method for presenting an audio-visual work by skimming through it. Mauldin's system performs content-based video analysis, including detecting the presence of a particular object or person ("human content"), to create a "skim output" that presents a modified version of the original video. However, Mauldin's primary mechanism for skimming is omitting non-representative frames rather than explicitly varying the playback rate of included frames based on content. Bhadkamkar was argued to supply this missing element, as it explicitly discloses varying the apparent display rate of an audio-visual work based on analyzing its content. For example, Bhadkamkar teaches slowing down playback for segments with a high probability of containing a particular speaker's voice and speeding it up for other segments.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because they are in the same technical field of audio-visual content presentation and address the similar problem of enabling efficient review. Petitioner asserted a POSITA would be motivated to improve Mauldin's content-skimming system by incorporating Bhadkamkar's more nuanced variable playback rate. This would allow for a better user experience, such as slowing down playback for important segments (e.g., when a person is detected) and speeding up playback for less important segments, a predictable improvement over simply dropping frames.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination. Both references involve signal processing of audio-visual data to control presentation. Integrating Bhadkamkar's display rate adjustment based on content detection into Mauldin's framework for content detection would be a straightforward application of known techniques to achieve predictable results.

Ground 2: Claim 2 is obvious over Mauldin in view of Bhadkamkar and Chan.

  • Prior Art Relied Upon: Mauldin (Patent 5,664,227), Bhadkamkar (Patent 5,893,062), and Chan (Patent 5,937,077).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1 to address dependent claim 2, which adds the limitation of "increasing the presentation rate during time periods in which there are no individuals in a predetermined number of frames." The combination of Mauldin and Bhadkamkar teaches increasing the presentation rate when content is deemed uninteresting (e.g., no person or specific speaker present). Petitioner argued that Chan teaches the final element: making this determination based on analyzing a "predetermined number of frames." Chan describes a flame detection system that accumulates votes over a series of frames before deciding if a flame is present or absent to improve accuracy and avoid false alarms from transient events in a single frame.
    • Motivation to Combine: A POSITA would be motivated to incorporate Chan's "multi-frame analysis" principle into the Mauldin/Bhadkamkar system to enhance its robustness. When deciding to speed up playback because no individuals are detected, relying on a single frame could lead to errors (e.g., a person is momentarily obscured or misidentified). By adopting Chan's approach, the system would wait for a "predetermined number of frames" to confirm the absence of individuals before increasing the playback speed, thereby preventing the user from mistakenly skipping over important content. This would be a predictable and desirable improvement to the system's reliability.
    • Expectation of Success: Success would be expected because applying multi-frame analysis to improve the accuracy of object detection is a well-known principle in video processing. A POSITA would find it straightforward to apply Chan's concept to the person-detection context of the Mauldin/Bhadkamkar system.

Ground 3: Claim 1 is obvious over Mauldin in view of Bhadkamkar and Aviv.

  • Prior Art Relied Upon: Mauldin (Patent 5,664,227), Bhadkamkar (Patent 5,893,062), and Aviv (Patent 5,666,157).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground provides an alternative basis for finding claim 1 obvious, specifically targeting the limitation "wherein the audio-visual work is output from a surveillance camera." While Petitioner contended Mauldin inherently suggests a surveillance context, this ground argues that Aviv explicitly teaches it. Aviv discloses trainable surveillance systems that use a "primary video camera" to monitor a zone and detect abnormal events. Petitioner asserted that Aviv's camera is, by definition, a surveillance camera.
    • Motivation to Combine: A POSITA implementing the audio-visual skimming system of Mauldin and Bhadkamkar would naturally look to a common and logical application for such technology, such as security and surveillance. Aviv provides an explicit teaching of using a camera in a surveillance system. It would have been obvious to a POSITA to source the audio-visual work for the Mauldin/Bhadkamkar processing system from a dedicated surveillance camera as taught by Aviv to create a complete surveillance and review system.
    • Expectation of Success: This combination would have been a predictable integration of known technologies. Combining a video processing method (Mauldin/Bhadkamkar) with a standard video source for a target application (Aviv's surveillance camera) would yield the expected result of an automated video surveillance review system.

  • Additional Grounds: Petitioner asserted an additional ground (Ground 4) arguing that claim 2 is obvious over the combination of Mauldin, Bhadkamkar, Aviv, and Chan. This ground combines the arguments from Grounds 2 and 3, using Chan to teach the "predetermined number of frames" limitation and Aviv to teach the "surveillance camera" source.

4. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1 and 2 of the ’380 patent as unpatentable.