PTAB

IPR2020-00861

Apple Inc v. Corephotonics Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dual Aperture Zoom Digital Camera with Video Support and Switching/Non-Switching Dynamic Control
  • Brief Description: The ’898 patent describes a multiple aperture digital camera with two imaging sections: a Wide-angle and a Telephoto. The camera includes a controller configured to output a zoom video image that uses either only Wide image data or only Tele image data, depending on whether a “no-switching criterion” is fulfilled.

3. Grounds for Unpatentability

Ground 1: Obviousness over Golan, Martin, and Togo - Claims 1, 4, 8, 12, and 15 are obvious over [Golan](https://ai-lab.exparte.com/case/ptab/IPR2020-00861/doc/1005) in view of [Martin](https://ai-lab.exparte.com/case/ptab/IPR2020-00861/doc/1006) and [Togo](https://ai-lab.exparte.com/case/ptab/IPR2020-00861/doc/1010).

  • Prior Art Relied Upon: Golan (Application # 2012/0026366), Martin (Patent 8,081,206), and Togo (JP Application # 2011-55246).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Golan disclosed the foundational dual-aperture (Wide and Tele) zoom camera system that switches between sensors based on a zoom factor. To address the ’898 patent’s limitation of outputting a “transformed, digitally zoomed Tele image data,” Petitioner asserted that Martin taught registering and transforming an image from one viewpoint to align with another for a stable video display. To meet the key “no-switching criterion” limitation, Petitioner pointed to Togo, which taught overriding a switch to the telephoto lens if a criterion (e.g., subject distance) indicated that doing so would result in poor image quality.
    • Motivation to Combine: A POSITA would combine Golan’s base camera system with Martin’s image transformation techniques to create a more stable and seamless transition between the Wide and Tele views, a known objective in the art. Further, a POSITA would incorporate Togo’s image quality-based no-switching logic to solve the known problem of telephoto lenses producing poor quality images of close-up subjects, thereby improving the overall performance and predictability of Golan’s system.
    • Expectation of Success: The combination involved applying known image processing techniques to a standard dual-camera architecture to achieve predictable improvements in video stability and image quality.

Ground 2: Obviousness over Golan, Martin, Togo, and Border - Claims 11 and 19 are obvious over the combination of Golan, Martin, and Togo in view of [Border](https://ai-lab.exparte.com/case/ptab/IPR2020-00861/doc/1009).

  • Prior Art Relied Upon: Golan (Application # 2012/0026366), Martin (Patent 8,081,206), Togo (JP Application # 2011-55246), and Border (Application # 2008/0030592).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address claims 11 and 19, which required the camera controller to be further configured to combine Wide and Tele image data in still mode to create a “fused output image.” Petitioner argued that Border explicitly taught a method for improving still image quality in a dual-lens camera by combining, or fusing, a wide image and a telephoto image into a single composite image with higher resolution.
    • Motivation to Combine: Petitioner contended that a POSITA, having already designed the video-switching camera of Ground 1, would be motivated to add features to improve still image quality. A POSITA would look to known techniques like those in Border and apply its still-mode image fusion method to the base system of Golan, Martin, and Togo to achieve the benefit of higher-quality still images, a simple and predictable design choice.

Ground 3: Obviousness over Golan, Martin, Togo, and Parulski - Claims 10 and 20 are obvious over the combination of Golan, Martin, and Togo in view of [Parulski](https://ai-lab.exparte.com/case/ptab/IPR2020-00861/doc/1008).

  • Prior Art Relied Upon: Golan (Application # 2012/0026366), Martin (Patent 8,081,206), Togo (JP Application # 2011-55246), and Parulski (Patent 7,859,588).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 10, which required the Tele lens to have a total track length to effective focal length (TTL/EFL) ratio of less than one (a definitional characteristic of a telephoto lens), and claim 20, which involved combining image data from “only in focused areas.” Petitioner asserted that Parulski taught a dual-lens camera that explicitly used a compact telephoto lens for a small form factor. Parulski also taught a method of creating a fused image with a broadened depth of field by combining only the sharp, in-focus portions of images taken at different focal distances.
    • Motivation to Combine: A POSITA implementing the Tele lens in Golan’s system would have been motivated to use a standard, compact telephoto lens design as taught by Parulski to achieve miniaturization, a key goal in camera design. Additionally, to further improve still image quality, a POSITA would have been motivated to apply Parulski’s method of fusing focused-only areas to create images with enhanced depth of field.
  • Additional Grounds: Petitioner asserted that claim 9 is obvious over Golan, Martin, and Togo in view of Levey (Application # 2012/0019704), which taught adding user-selectable camera modes to the base combination.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was unwarranted because the petition presented new prior art and arguments not previously before the examiner. The core combination relied on Martin, Togo, and other references that were not considered during prosecution, which focused on a single reference (Shabtay). Petitioner contended these new references and combinations were material and not cumulative to the examined art, thus warranting review.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1, 4, 8-12, 15, 19, and 20 of the ’898 patent as unpatentable.