PTAB

IPR2019-01584

Google LLC v. Uniloc 2017 LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Motion Estimation for Digital Video Coding
  • Brief Description: The ’005 patent describes a method for performing motion estimation in video compression by concurrently processing multiple different prediction modes (e.g., frame and field prediction) based on a single search operation to determine an optimum prediction mode.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3, 5, 6, 8, 39, and 41 under 35 U.S.C. §102 by Hanami

  • Prior Art Relied Upon: Hanami (Patent 6,122,317).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hanami discloses every limitation of the challenged claims. Hanami’s stated objective is to provide a motion vector detector that can "simultaneously detect optimum vectors efficiently coded for a plurality of predictive modes in parallel with each other." Petitioner asserted this is the same allegedly novel concept of the ’005 patent. Hanami teaches performing motion estimation for multiple prediction modes (frame predictive, odd field predictive, and even field predictive) in parallel from a single search operation. Specifically, Hanami discloses calculating separate evaluation values for each prediction mode and then using a compare part to determine the optimum mode, which it defines as the mode having the "minimum evaluation value." Petitioner contended this process directly maps to the limitations of independent claims 1, 39, and 41, which require concurrently performing motion estimation for different modes to determine an optimum mode and generating a motion vector in response.
    • Key Aspects: Petitioner argued that dependent claims are also anticipated. For claim 2, Hanami’s disclosure of a video data structure with sequence, GOP, picture, slice, and macroblock layers is consistent with the MPEG standard. For claim 5, Hanami’s disclosure of variable-length coding for motion vectors is identical to the MPEG-2 standard, confirming its motion coding is performed in accordance with an MPEG standard.

Ground 2: Obviousness of Claims 2 and 5 under 35 U.S.C. §103 over Hanami in view of Mitchell

  • Prior Art Relied Upon: Hanami (Patent 6,122,317) and Mitchell (MPEG Video Compression Standard textbook, 1996).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that, to the extent the Board finds Hanami does not explicitly teach that its pixel arrays have a size and structure defined by an MPEG standard (claim 2) or that its motion coding is performed in accordance with an MPEG standard (claim 5), it would have been obvious for a person of ordinary skill in the art (POSITA) to modify Hanami’s system to be compliant. Hanami discloses the underlying video coding techniques, and Mitchell describes the prevailing MPEG standard and the strong industry reasons for its adoption.
    • Motivation to Combine: A POSITA would combine the teachings because Mitchell established that standardization was a "natural development" and a "key driving force" in digital video technology to lower costs, ensure interoperability, and reduce barriers to deployment. At the time of the invention, MPEG was the most widely accepted standard. Therefore, a POSITA would have been motivated to ensure that any new video coding technique, such as that in Hanami, was compliant with the MPEG standard to achieve the predictable benefits of market acceptance and efficiency.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because Hanami’s disclosed encoder architecture already contained the fundamental components (e.g., motion compensation predictor, quantizer, etc.) required for an MPEG-compliant encoder. Modifying Hanami to strictly adhere to MPEG sizing and structural definitions would have been a predictable application of known, standardized techniques.

4. Key Claim Construction Positions

  • Petitioner stated that no express constructions were necessary but addressed constructions proposed in two other pending IPRs against the ’005 patent.
  • “concurrently perform[ing]... motion estimation”: Petitioner adopted a proposed construction of “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.” Petitioner argued Hanami’s parallel processing of different predictive modes from a single search operation meets this construction.
  • “optimum”: Petitioner argued Hanami meets proposed constructions of “best or most suitable” and “the prediction mode that yields the smallest value of an error metric.” Hanami explicitly teaches selecting the prediction mode with the "minimum evaluation value" to achieve "excellent coding efficiency."

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution based on other pending IPRs against the same patent (IPR2019-01126 and IPR2019-01270). Petitioner asserted that under the General Plastic factors, institution is favored because this is Google’s first IPR against the ’005 patent, it was filed well before any preliminary response or institution decision in the other IPRs (preventing any tactical advantage), and the prior art asserted is different.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5, 6, 8, 39, and 41 of the ’005 patent as unpatentable.