PTAB

IPR2020-01396

Samsung Electronics Co Ltd v. Clear Imaging Research LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus to Correct Blur in All or Part of a Digital Image by Combining Plurality of Images
  • Brief Description: The ’699 patent discloses methods and apparatuses for correcting image blur in digital images. The technology involves combining multiple captured images to create a final photographic image where a designated main subject is substantially blur-free and other areas are blurred.

3. Grounds for Unpatentability

Ground 1: Claims 1-30 are obvious over Aizawa, Hyodo, and Mitsufumi

  • Prior Art Relied Upon: Aizawa (Application # 2001/0013895), Hyodo (Patent 7,034,881), and Mitsufumi (Japanese Patent Publication No. 2003209727).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references taught all elements of the challenged claims. Aizawa was asserted to teach the core method of capturing multiple images with different focal points and combining them into a single reconstructed image where the blur of certain regions is suppressed or intensified (e.g., a focused foreground and blurred background). To meet the limitation of designating a main subject via a viewfinder, Petitioner pointed to Hyodo, which disclosed a digital camera with a touch screen LCD viewfinder. In Hyodo, a user could touch a "principal subject" on the screen to designate it for focusing. Petitioner contended that combining Hyodo’s user-friendly touch interface with Aizawa’s image processing technique would render the claimed invention obvious. Mitsufumi was cited as additional art teaching the compositing of separately focused foreground and background images to create a final image with a desired amount of out-of-focus blur ("bokeh"), reinforcing the general concept. For dependent claims, Petitioner argued that features like calculating pixel values (claim 2), shifting images for alignment (claim 6), and indicating the subject with an on-screen frame (claim 5) were also disclosed or suggested by the prior art combination.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Hyodo's touch screen viewfinder with Aizawa's image processing system for predictable reasons. The primary motivations were to improve the camera's ease of use and ergonomics by allowing a user to frame a shot on a larger LCD screen rather than a small optical viewfinder, and to provide a more direct and intuitive method for a user to designate the subject of interest by simply touching it on the screen. This modification was presented as a common-sense improvement to make the camera easier and more comfortable to operate.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success in making this combination. Both Aizawa and Hyodo described digital cameras capable of displaying preview images, and Hyodo explicitly taught that an LCD could be integrated with a touch panel to receive user input in a camera context. As the integration involved using known components for their intended and well-understood functions, success would have been expected.

4. Key Claim Construction Positions

  • “processor ... configured to” (claims 9, 24): Petitioner noted an ongoing dispute in parallel district court litigation regarding whether this term invokes 35 U.S.C. §112, ¶ 6. For the purposes of the IPR, Petitioner stated it would rely on the presumption that the term should be given its plain and ordinary meaning, consistent with the Patent Owner's litigation position, thereby avoiding the §112, ¶ 6 issue in the IPR proceeding.
  • “designating ... a main subject” (claims 1, 9, 17, and 24): Petitioner proposed this term should be construed to mean "identifying an object to use as a reference point for aligning images to correct blur." This construction was argued to be supported by the patent's specification and was central to Petitioner's argument that Aizawa's image registration/alignment process, when directed by user input as taught in Hyodo, met this claim limitation.

5. Arguments Regarding Discretionary Denial

  • Petitioner presented extensive arguments that discretionary denial under Fintiv would be inappropriate. It was argued that the co-pending district court case was at a very early stage, with no claim construction order issued and discovery not yet closed. Petitioner asserted that institution would simplify the district court case and likely lead to a stay. Furthermore, Petitioner stipulated that if the IPR was instituted, it would not pursue the same invalidity grounds in district court, eliminating concerns of duplicative efforts. Petitioner also noted that the IPR addresses all 30 claims of the patent, whereas the district court case would likely focus on a much smaller subset, meaning the IPR provides a more efficient and complete resolution of the patent's validity.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’699 patent as unpatentable under 35 U.S.C. §103.