Google LLC v. Kewazinga Corp

1. Case Identification

• Case #: IPR2021-00525
• Patent #: 6,522,325
• Filed: February 16, 2021
• Petitioner(s): Google LLC
• Patent Owner(s): Kewazinga Corp.
• Challenged Claims: 1-30

2. Patent Overview

• Title: Navigable Telepresence Method and System Utilizing an Array of Cameras
• Brief Description: The ’325 patent describes a telepresence system that uses an array of cameras to capture images of an environment. The system allows multiple users to simultaneously and independently navigate through the environment by selecting and displaying stored images based on their respective inputs.

3. Grounds for Unpatentability

Ground 1: Claims 4, 5, 13, and 14 are anticipated by Kumar

• Prior Art Relied Upon: Kumar (Patent 6,522,787).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Kumar, which describes a system for rendering synthesized views of a scene from multiple images, discloses every element of the challenged claims. Independent claim 4 recites a device with a camera array, memory for storing additional source output (e.g., computer graphics), and a processor to mix the camera output with the additional source output via mosaicing based on user input. Petitioner asserted Kumar teaches all of these elements, including an array of cameras with different perspectives, storing a "second image" (the additional source), and a CPU that composites the images. Independent claim 5 recites a system for remote seamless viewing using an array of cameras with overlapping fields of view, an interface for path selection, and a display for sequentially mosaicing images to create a seamless view. Petitioner contended Kumar’s system for generating a seamless view via an image tweening/mosaicing process from multiple camera viewpoints meets these limitations.
  • Key Aspects: Claims 13 and 14 are analogous to claims 4 and 5, respectively, but substitute "tweening" for "mosaicing." Petitioner argued Kumar explicitly teaches an "image tweening process" that generates a synthetic image, thus anticipating these claims as well.

Ground 2: Claims 1-3, 6-7, 10-12, 15-16, and 19-21 are obvious over Kumar and Kellogg

• Prior Art Relied Upon: Kumar (Patent 6,522,787) and Kellogg (a 1993 MIT thesis titled "Visual Memory").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Kumar discloses the foundational telepresence system, including a camera array, image storage, and a processor for creating synthesized views, as established in Ground 1. However, Kumar's system is primarily described from a single-user perspective. Kellogg was argued to remedy this deficiency by teaching a "visual memory" system for storing video data that explicitly supports concurrent users and independent read/write access. The combination, Petitioner argued, renders obvious the limitations in independent claims 1 and 19 related to providing a "first user" and a "second user" with independent displays and navigation control. Kellogg's disclosure of multiple user interfaces and concurrent access was alleged to map directly onto the patent's requirements for simultaneous, independent navigation by two users.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to enhance Kumar's image processing system with the known and advantageous feature of multi-user access and concurrency control taught by Kellogg. Adding multi-user support was presented as a predictable improvement to make Kumar’s system more versatile.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because Kumar already included a video storage device. Augmenting or substituting this component with Kellogg's more advanced visual memory system, which was designed for the same purpose of storing and retrieving image data, would be a straightforward integration.

Ground 3: Claims 8-9, 17-18, and 22-30 are obvious over Kumar, Kellogg, and Conley

• Prior Art Relied Upon: Kumar (Patent 6,522,787), Kellogg (a 1993 MIT thesis), and Conley (Patent 7,843,497).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Kumar and Kellogg by adding Conley. Petitioner argued Conley, which is directed to an array-camera motion picture device, provides the specific physical camera array configurations and functionalities recited in the remaining claims. Key teachings from Conley included using multiple, "removable" camera arrays (e.g., mounted on moving platforms), positioning arrays at different lengths from the environment to simulate forward/backward movement, and arranging cameras in specific shapes (e.g., a circular "Ring of Video Cameras"). For example, claim 22 requires a "plurality of removable arrays of cameras," which Petitioner contended was taught by Conley's disclosure of cameras mounted on moving platforms or gondolas. Claim 25 requires a "cylindrical shape," which was allegedly disclosed by Conley’s ring of cameras.
  • Motivation to Combine: A POSITA looking to build a robust, multi-user telepresence system (based on Kumar and Kellogg) would be motivated to incorporate Conley’s teachings to provide more dynamic and immersive navigation. Conley's methods for arranging and moving camera arrays offered known techniques to achieve sophisticated visual effects, such as simulating complex user movement, which would be a desirable feature for the Kumar/Kellogg system.
  • Expectation of Success: The combination was argued to be predictable. Since Conley teaches image storage and retrieval from its camera arrays, a POSITA would find it straightforward to substitute or augment Conley’s storage with the superior multi-user visual memory of Kellogg and integrate it into the image processing framework of Kumar.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate because the parallel district court litigation had no trial date or case schedule set beyond claim construction. Petitioner asserted that it would address any further arguments from the Patent Owner regarding case schedule or trial issue overlap if and when they were raised.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-30 of the ’325 patent as unpatentable.