PTAB

IPR2019-01519

LG Electronics Inc v. Uniloc 2017 LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Displaying an Image on a Screen with an Adapted Size
  • Brief Description: The ’408 patent discloses a receiver system for processing a broadcasted signal that contains both image data and control data. This control data specifies a partition of "important subject matter" within the image, and the receiver uses a re-sampling unit to adapt the size of this partition for display based on a variable re-sampling rate.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 and 6-11 are anticipated by Kitaura under 35 U.S.C. §102.

  • Prior Art Relied Upon: Kitaura (Japanese Published Unexamined Patent Application S60-192479).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kitaura, which describes a system for converting high-definition television signals for display on standard-definition screens, discloses every limitation of the challenged claims. Kitaura's television signal receiving apparatus functions as the claimed "receiver." The signal in Kitaura includes "conversion control signal" data specifying the position, enlargement ratio, and reduction ratio of a "conversion area," which Petitioner asserted constitutes the claimed "control data" defining the location and size of the "important subject matter." Furthermore, Kitaura’s conversion processing circuitry, which modifies the signal read-out rate based on the control data (e.g., for 2X or 4X enlargement), performs the function of the claimed "re-sampling unit" that operates at a "variable re-sampling rate." This re-sampling is adapted according to a criterion—specifically, whether conversion is "needed or unneeded" based on the properties of the destination screen, thus resizing the image to fit. Dependent claims were also argued to be disclosed, such as adapting to user input (visual acuity) via a manual conversion apparatus.

Ground 2: Claims 1-11 are obvious over Kitaura in view of Kato under 35 U.S.C. §103.

  • Prior Art Relied Upon: Kitaura (Japanese Application S60-192479) and Kato (Patent 6,016,362).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that to the extent Kitaura fails to explicitly teach certain limitations, Kato supplies them. Specifically, if Kitaura’s "enlargement/reduction ratio" is found insufficient to teach control data "defining the size" of the partition, Kato explicitly discloses multiplexing an image with "cutting-out position information" that includes a "width" and "height" for a rectangular area. This directly teaches defining the partition's size. Additionally, for claim 5's "discarding unit being connected between said decoder and said re-sampling unit," Petitioner argued that Kato's "cutter 13" is precisely such a unit. In Kato's architecture, the cutter is placed after a demultiplexer/decoder and before an enlarger (re-sampler) to cut out portions of the image based on the position information.
    • Motivation to Combine: A POSITA would combine Kitaura and Kato because both address the same problem: converting video signals for different aspect ratios while preserving the program producer's intended viewing area. A POSITA would have been motivated to incorporate Kato’s explicit width/height data into Kitaura's control signal to more precisely define the conversion area, ensuring the producer's intent is maintained across various screen sizes. Similarly, incorporating Kato's dedicated "cutter" architecture into Kitaura's system would be a known design choice to offload processing, increase throughput, and create a more modular design—all predictable benefits.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Integrating Kato's specific size parameters and cutter module into Kitaura's framework involves applying known signal processing techniques to achieve the predictable result of a more robust and efficient video conversion system.
  • Additional Grounds: Petitioner asserted that all claims are also obvious over Kitaura alone, arguing that even if certain elements are not explicitly disclosed, they represent obvious modifications. For example, combining Kitaura's discrete processing circuits into a single "decoder" or "re-sampling unit" would have been an obvious design choice to reduce cost and latency.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-11 of the ’408 patent as unpatentable.