PTAB

IPR2020-00866

Avigilon USA Corp v. Canon Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Transmitting video data
  • Brief Description: The ’952 patent discloses a method for transmitting video data over IP networks by dividing a video frame into multiple partitions (“tiles”). The system transmits a notification with spatial information to a client, which then selects a Region of Interest (ROI) and requests the corresponding video tiles from a server.

3. Grounds for Unpatentability

Ground 1: Obviousness over Irie and Van Deventer - Claims 7 and 11-14 are obvious over Irie in view of Van Deventer.

  • Prior Art Relied Upon: Irie (Japanese Application # 2009-212821) and Van Deventer (Patent 9,860,572).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the challenged claims, which all depend from un-challenged independent claim 3, are obvious over the combined teachings of Irie and Van Deventer. The patentability of the ’952 patent allegedly hinged on a specific limitation added during prosecution: representing the spatial position of video partitions using a pixel value relative to a reference pixel. Petitioner contended this feature was not novel and was disclosed by the prior art.
      • Independent Claim 3 Limitations: Petitioner asserted that Irie teaches the core method of claim 3. Irie describes a system that divides a video frame into multiple blocks, sends "video division information" (a notification) to a client including "information on the position of each block in the frame," receives a request for a selected ROI from the client, and transmits the corresponding video data. Petitioner argued that Irie's disclosure of position information as "(x, y) coordinates" inherently teaches the claimed "pixel position" limitation, as such coordinates are fundamentally represented by pixels on a display. Irie's Figure 10 was cited as illustrating individual blocks identified by pixel positions relative to a reference point (the frame origin).
      • Dependent Claim 7 (Different Sized Regions): While Irie teaches that there is "no restriction on the sizes of the video blocks," Van Deventer was cited for its explicit disclosure that spatial segment frames may have "different segment frame dimensions," such as smaller frames near the center of an image and larger frames at the edges.
      • Dependent Claims 11 & 12 (URLs/HTTP Addresses): Petitioner argued that while Irie discloses using multicast addresses for requests, Van Deventer teaches the use of a "spatial manifest file" that contains location information, specifically citing "e.g. URLs," for retrieving video segment streams. Van Deventer also explicitly teaches the use of various protocols, including HTTP, to deliver content. A POSITA would have found it obvious to incorporate Van Deventer's URL-based manifest file into Irie's system to manage requests.
      • Dependent Claims 13 & 14 (Multiple Time Periods): Petitioner contended that Irie's system inherently sends notifications corresponding to each time period of a video frame. Van Deventer was cited for explicitly teaching that spatial information can change over time and requires updated notifications. Van Deventer describes sending an initial spatial manifest file and later sending an "updated" manifest file to the client, which corresponds to the claimed first and second notifications for different time periods.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Irie and Van Deventer because they address the same problem of streaming high-resolution, tiled video and are complementary. Irie provides a foundational multicast system, while Van Deventer provides a more detailed implementation using a "spatial manifest file" suitable for various content delivery networks. Petitioner noted that Van Deventer cites Irie on its face, indicating a POSITA would have been aware of both and motivated to combine Van Deventer’s sophisticated manifest file structure with Irie’s core system to improve flexibility and network compatibility.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in combining the references because their methods for segmenting and delivering video content are compatible and complementary. Integrating Van Deventer’s detailed manifest file into Irie’s framework was presented as a straightforward application of known techniques.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 7 and 11-14 of the ’952 patent as unpatentable.