PTAB

IPR2020-01397

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 an Image
  • Brief Description: The ’944 patent relates to correcting image blur by capturing and combining a plurality of digital images. The disclosed method creates a final composite image where a designated main subject is substantially blur-free while other areas of the image are blurred.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4, 6, and 9 are obvious over Kitamura, Suh, and Toyoda

  • Prior Art Relied Upon: Kitamura (Application # 2001/0022860), Suh (Patent 6,977,687), and Toyoda (Japanese Application # H9-181966).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this combination taught all limitations of the challenged independent claims. Kitamura was asserted to teach the core method of capturing multiple images at slightly different focus positions and combining them to generate a composite image with a focused foreground and a blurred background. Suh was cited for its disclosure of a digital camera with a touch-screen LCD viewfinder, which allows a user to designate a focus subject by touching its location on the preview image. Toyoda was argued to teach a method for digitally applying a "bokeh" effect to an image based on lens parameters (e.g., focal length, F-number) to simulate the blur produced by a large-aperture lens.
    • Motivation to Combine: A POSITA would combine Suh’s intuitive touch-screen interface with Kitamura’s camera to improve ergonomics and ease of use, as it eliminates the need for a traditional viewfinder. A POSITA would incorporate Toyoda’s lens parameter-based blur processing into Kitamura’s system to create more realistic and controllable blur effects, allowing a small, lightweight camera to produce images with an aesthetic quality similar to those from cameras with large, heavy lenses.
    • Expectation of Success: Petitioner contended a POSITA would have an expectation of success because all references operated within the predictable field of digital image processing, and combining a common user interface feature (touch focus) with known image combination techniques was straightforward.

Ground 2: Claims 3, 5, 8, and 10 are obvious over Kitamura, Suh, Toyoda, and Manabe

  • Prior Art Relied Upon: Kitamura (Application # 2001/0022860), Suh (Patent 6,977,687), Toyoda (Japanese Application # H9-181966), and Manabe (Application # 2005/0018927).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Manabe to the primary combination to address dependent claims related to pixel processing. Petitioner argued Manabe taught capturing a plurality of frames, identifying a reference point in each, aligning the frames, and combining them via arithmetic addition of corresponding pixel values. This process was asserted to meet claim limitations requiring the calculation of pixel values in the final image based on pixel values from the source images.
    • Motivation to Combine: A POSITA would combine Manabe's alignment and pixel-averaging techniques with the Kitamura/Suh/Toyoda system to improve the final image quality. This combination would correct for minor misalignments caused by hand shake and would produce a composite image with a higher signal-to-noise ratio and greater dynamic range.
    • Expectation of Success: Success was expected as Manabe's techniques were well-known methods for enhancing composite images and were directly applicable to Kitamura's process of combining multiple captured frames.

Ground 3: Claims 2 and 7 are obvious over Kitamura, Suh, Toyoda, and Noriyuki

  • Prior Art Relied Upon: Kitamura (Application # 2001/0022860), Suh (Patent 6,977,687), Toyoda (Japanese Application # H9-181966), and Noriyuki (Japanese Publication No. 2002057933).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Noriyuki to address limitations requiring a "second user input" that designates the "second subject" (e.g., the background) in the combined image. Petitioner argued Noriyuki taught a system where a user could select a preferred bokeh style from a menu of indicators displayed on an LCD (e.g., "foreground focused with high bokeh in background"). Selecting an option that focused the background was argued to be a second user input designating the background as the subject of interest.
    • Motivation to Combine: A POSITA would incorporate Noriyuki’s user-selectable blur modes into the base combination to provide the photographer with greater creative control over the final image. This would allow the user to modify the blur effect after an initial composite image is generated, satisfying user preferences for different aesthetic outcomes.
    • Expectation of Success: Providing selectable image effect modes was a common design choice in digital cameras, and Noriyuki demonstrated this specific functionality in the context of bokeh control, making its integration into the Kitamura system predictable.
  • Additional Grounds: Petitioner asserted further obviousness challenges based on combinations of Kitamura, Noriyuki, Toyoda, and Manabe. Petitioner also presented alternative arguments (Grounds 2A-2C) applying the same prior art combinations to a different proposed claim construction for the term "designating...a...subject."

4. Key Claim Construction Positions

  • "designating ... a ... subject": Petitioner argued this term should be construed as "identifying an object to use as a reference point for aligning images to correct blur." Petitioner noted this construction was advanced for its alternative grounds (2A-2C), while its primary grounds (1A-1E) were based on the Patent Owner's apparent litigation position that no special construction was necessary.
  • "[processor/user interface] ... configured to": For the purpose of the IPR, Petitioner applied the plain and ordinary meaning to these terms. However, Petitioner reserved the right to argue that these terms should be interpreted under 35 U.S.C. §112, ¶6 in the co-pending district court litigation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under the Fintiv factors. The core arguments were that the co-pending district court case was at a very early stage with no claim construction orders issued and a trial date set for after the statutory deadline for a Final Written Decision (FWD). Petitioner further argued that it had made a substantial investment in preparing the petition and had stipulated that it would not pursue the same invalidity grounds in district court if the IPR was instituted, thereby avoiding duplicative efforts and conserving judicial resources.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’944 patent as unpatentable under 35 U.S.C. §103.