PTAB
IPR2020-00866
Avigilon USA Corporation v. Canon Inc.
1. Case Identification
- Case #: IPR2020-TBD
- Patent #: 10,135,952
- Filed: April 24, 2020
- Petitioner(s): Avigilon USA Corporation, Avigilon Corporation, and Motorola Solutions, Inc.
- Patent Owner(s): Canon Inc.
- Challenged Claims: 7, 11-14
2. Patent Overview
- Title: Transmitting Tiled Video Data with Positional Information
- Brief Description: The ’952 patent discloses a method for transmitting video data over a network by dividing a video frame into multiple independent partial videos or "tiles." The system sends a notification to a client containing spatial information for the tiles, allowing the client to select a "Region of Interest" and request only the corresponding tiles for viewing.
3. Grounds for Unpatentability
Ground 1: Claims 7 and 11-14 are obvious over Irie in view of Van Deventer.
- Prior Art Relied Upon: Irie (Japanese Patent Application Publication No. 2009-212821) and Van Deventer (Patent 9,860,572).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that the combination of Irie and Van Deventer taught all limitations of the challenged claims, which all depend from independent claim 3. Petitioner argued the patentability of the ’952 patent hinged on a specific claim limitation added during prosecution: representing a tile’s position by a value based on a reference pixel position on the frame. Petitioner contended that Irie, which was not before the examiner during the original prosecution, expressly taught this exact functionality.
- Claim 3 (Base Claim): Petitioner argued that Irie alone disclosed all elements of claim 3. Irie taught a system that divides a video frame into multiple blocks (tiles), transmits "video division information" to a client (the "notification"), and then transmits the specific blocks requested by the client based on a selected Region of Interest (ROI). Critically, Petitioner asserted that Irie’s "video division information" included position information for each block (x, y coordinates) that could be represented in pixels. Petitioner pointed to Irie's figures and description to argue this taught the allegedly novel limitation of using a pixel position relative to a reference (e.g., the frame origin) to identify each tile.
- Claim 7 (Different Sized Tiles): Petitioner argued that while Irie’s system was compatible with tiles of different sizes, Van Deventer explicitly disclosed this feature. Van Deventer taught that "spatial segment frames in a segment group may have different segment frame dimensions," such as smaller frames near the center of an image and larger frames at the edges. This combination, Petitioner argued, rendered the limitation obvious.
- Claims 11 & 12 (URLs/HTTP): Petitioner contended that a person of ordinary skill in the art (POSITA) would have understood Irie's "address information" (e.g., multicast address and port number) to be a form of locator like a URL. The argument was strengthened by Van Deventer, which explicitly disclosed using URLs and specific protocols like HTTP and RTSP within a "spatial manifest file" to locate and retrieve video segment streams. A POSITA would find it obvious to use the specific HTTP addresses taught by Van Deventer in the system of Irie.
- Claims 13 & 14 (Multiple Time Periods): Petitioner argued that Van Deventer taught sending multiple or updated notifications for different time periods. Van Deventer described how spatial segments in a video stream can change over time and must be identified accordingly, for instance, by sending an initial spatial manifest file and later an "updated" file. Petitioner asserted it would be obvious to apply this concept to Irie's system, thereby teaching the transmission of distinct notifications with spatial position and size information corresponding to different time periods.
- Motivation to Combine: Petitioner argued a POSITA would combine the references because they described complementary methods for video streaming. Irie provided a system for delivering tiled video for ROI selection, while Van Deventer provided a sophisticated "spatial manifest file" for describing and retrieving such tiled content, explicitly mentioning varied tile sizes and network protocols. A POSITA would combine Van Deventer's flexible manifest file with Irie’s system to improve its functionality and adaptability across different content-delivery networks. Furthermore, Petitioner noted that Van Deventer cited Irie on its face, indicating the two were in the same field of endeavor.
- Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in combining the teachings, as the two systems addressed related problems in video streaming with technologically compatible solutions.
- Prior Art Mapping: Petitioner asserted that the combination of Irie and Van Deventer taught all limitations of the challenged claims, which all depend from independent claim 3. Petitioner argued the patentability of the ’952 patent hinged on a specific claim limitation added during prosecution: representing a tile’s position by a value based on a reference pixel position on the frame. Petitioner contended that Irie, which was not before the examiner during the original prosecution, expressly taught this exact functionality.
4. Relief Requested
- Petitioner requested institution of an inter partes review and cancellation of claims 7 and 11-14 of the ’952 patent as unpatentable under 35 U.S.C. §103.