PTAB

IPR2019-01270

Sling TV LLC v. Uniloc 2017 LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Motion Estimation for Video Encoding
  • Brief Description: The ’005 patent relates to a method and system for video encoding that performs motion estimation for multiple different prediction modes (e.g., frame prediction, field prediction) concurrently. The purported novelty is performing these estimations for a single macroblock during the same search operation, allowing for the efficient determination of an optimum prediction mode.

3. Grounds for Unpatentability

Ground 1: Claims 1-16 and 39-42 are anticipated under 35 U.S.C. §102 by Ishihara.

  • Prior Art Relied Upon: Ishihara (“A Half-pel Precision MPEG2 Motion-Estimation Processor with Concurrent Three-Vector Search,” a 1995 IEEE journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ishihara disclosed every element of the challenged claims. Specifically, Ishihara described an MPEG-2 motion estimation processor that “supports all prediction modes… and estimates three vectors concurrently.” Petitioner contended that Ishihara’s hardware, which uses a summation circuit to simultaneously generate error metrics (Mean Absolute Difference) for both frame and field prediction modes from a single search operation, is functionally and structurally identical to the method disclosed in the ’005 patent. A minimum-value detector in Ishihara then selects the best prediction mode and corresponding motion vector, directly mapping to the claim limitation of determining an "optimum prediction mode."
    • Key Aspects: Petitioner emphasized that the ’005 patent’s own figures depicting the concurrent search process are functionally indistinguishable from diagrams in Ishihara illustrating its summation circuit, demonstrating that the allegedly novel concept was already disclosed.

Ground 2: Claims 1-16 and 39-42 are obvious over Ishihara in view of Ishihara798.

  • Prior Art Relied Upon: Ishihara (a 1995 IEEE journal article) and Ishihara798 (Patent 6,674,798).

  • Core Argument for this Ground:

    • Prior Art Mapping: To the extent Ishihara was found not to anticipate the claims, Petitioner argued the claims would have been obvious by combining its teachings with Ishihara798. Ishihara provided the foundational MPEG-2 motion estimation processor capable of concurrent vector estimation. Ishihara798, in turn, explicitly taught a "motion vector detecting device capable of accommodating a plurality of predictive modes" where it is "possible to simultaneously detect motion vectors according to a plurality of predictive modes." Ishihara798 further disclosed using a comparison part to analyze the evaluation function values from the parallel operations to decide the "optimum predictive mode."
    • Motivation to Combine: A POSITA would combine these references because they were created by the same inventors, address the same technical problem of efficient motion estimation, and share the common objective of improving video compression performance without increasing computational cost or device complexity. Ishihara798 was presented as teaching a known, compatible technique for selecting an optimal mode that would naturally be applied to the processor disclosed in Ishihara.
    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success, as the combination involved applying a known technique (selecting an optimum mode from parallel computations, as taught by Ishihara798) to a similar and compatible device (the processor in Ishihara) to achieve the predictable result of improved mode selection.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 1-16 and 39-42 based on Ishihara in view of Ishihara486 (Patent 5,949,486) and Ishihara in view of Bellifemine (WO 89/42137). These grounds relied on similar theories that Ishihara486 and Bellifemine provided the missing element of selecting an optimum mode from concurrently calculated results.

4. Key Claim Construction Positions

  • "concurrently perform[ing]... motion estimation...": Petitioner argued this key phrase, central to the patent’s alleged novelty, should be construed to mean "performing motion estimation according to each of a plurality of prediction modes during the same search operation for a given macroblock, without performing a separate search on the same macroblock for each such mode." This construction was crucial to Petitioner’s argument, as it framed the analysis around the efficiency of the search operation itself, a feature Petitioner alleged was fully disclosed in the prior art.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial by distinguishing its petition from a previously filed IPR by a different petitioner (Unified Patents, IPR2019-01126). Petitioner contended that its petition was not cumulative because it presented a new anticipation ground under §102, whereas the Unified Patents petition only asserted obviousness under §103. Furthermore, Petitioner’s obviousness grounds relied on different combinations of prior art not addressed in the earlier petition, and thus presented distinct unpatentability challenges.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-16 and 39-42 of Patent 6,519,005 as unpatentable.