PTAB

IPR2021-00524

Google LLC v. Kewazinga Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Telepresence Systems and Methods
  • Brief Description: The ’234 patent discloses a system that allows multiple users to virtually navigate through imagery of an environment captured by an array of cameras. The system generates mosaic imagery to simulate movement and provide users with a sense of "telepresence."

3. Grounds for Unpatentability

Ground 1: Anticipation over Moezzi-1 - Claims 1, 13, and 14 are anticipated by Moezzi-1 under 35 U.S.C. §102.

  • Prior Art Relied Upon: Moezzi-1 (Patent 5,745,126).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Moezzi-1, which teaches a system for synthesizing virtual video images from multiple cameras, discloses every limitation of the challenged claims. Specifically, Moezzi-1 was asserted to teach a system that provides at least two users with different views of a remote environment simultaneously and independently. The system includes a "video database" (electronic storage), a "UNIX workstation" (processing elements), and a "viewer interface" that receives user inputs to select perspectives. Petitioner contended that Moezzi-1’s process of combining images from multiple cameras with overlapping fields of view to construct a 3-D model, from which 2-D images are rendered, constitutes the claimed "generating mosaic imagery." The ability for a viewer to virtually "swoop" onto a playing field or "circle" a stadium in Moezzi-1 was argued to meet the limitation of navigating along a view of the environment.

Ground 2: Obviousness over Moezzi-1, Moezzi-2, Kellogg, and Peleg - Claims 1-3, 8, 10-11, 13-16, 18, 21, 23, 25-26, and 28-29 are obvious over Moezzi-1, Moezzi-2, Kellogg, and Peleg under 35 U.S.C. §103.

  • Prior Art Relied Upon: Moezzi-1 (Patent 5,745,126), Moezzi-2 (Patent 5,850,352), Kellogg (a 1993 MIT thesis titled "Visual Memory"), and Peleg (Patent 6,532,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Moezzi-1 discloses the majority of the claim limitations, establishing a base telepresence system. The combination with the other references was argued to supply the remaining features. Moezzi-2, which incorporates Moezzi-1 by reference, was cited for its explicit teachings on creating immersive video via mosaicing imagery from multiple cameras. Kellogg was introduced for its disclosure of a "visual memory" system supporting concurrent access by multiple users, which would have been a known solution for enhancing the multi-user database functions of Moezzi-1. Peleg was cited for teaching advanced techniques for generating smooth panoramic mosaics, including aligning, merging, warping, and interpolating images from different viewpoints to improve the visual output. For example, Peleg's teachings on aligning and merging imagery were argued to render obvious the limitations of claim 2. Moezzi-2's teachings on compositing video data were argued to render obvious the compositing limitations of claims 8 and 23.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references to achieve a predictable and improved result. A POSITA would combine the related Moezzi-1 and Moezzi-2 references to leverage Moezzi-2’s detailed mosaicing descriptions. A POSITA would integrate Kellogg’s concurrency control to improve the multi-user functionality of the Moezzi systems. Finally, a POSITA would incorporate Peleg’s advanced mosaic generation techniques to enhance the quality and smoothness of the virtual navigation experience, a known problem in the art.
    • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success. The combination involved applying known database improvements (Kellogg) and image processing techniques (Peleg) to a base system (Moezzi-1 and Moezzi-2) to achieve their expected functions. The mosaicing techniques of Peleg were designed to work with overlapping camera images of the type disclosed in Moezzi.

4. Key Claim Construction Positions

  • "View of the environment": Petitioner proposed this term means "images arranged to represent a scene." This construction was argued to be consistent with the ’234 patent’s focus on virtual navigation through imagery, not physical space.
  • "View through the environment": Petitioner proposed this term means "an ordered sequence of images arranged to represent a user selected path within a scene." This construction was based on specification examples of users moving along a path by viewing stored or generated images in sequence.
  • "Navigate/Navigation": Petitioner proposed these terms mean "select different images for viewing in a determined order" and "selection of different images for viewing in a determined order," respectively. This emphasizes the virtual nature of the user's movement as a selection process rather than physical traversal.

5. Arguments Regarding Discretionary Denial

  • Petitioner noted that the related district court litigation had no trial date or case schedule set beyond claim construction. Petitioner stated its intent to address any arguments from the Patent Owner regarding discretionary denial based on the case schedule at a later time.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 8, 10-11, 13-16, 18, 21, 23, 25-26, and 28-29 of the ’234 patent as unpatentable.