PTAB

IPR2021-00526

Google LLC v. Kewazinga Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Navigable Camera Array Telepresence System
  • Brief Description: The ’226 patent describes a telepresence system that uses an array of cameras, with each camera capturing a view of an environment from a progressively different perspective. The system allows multiple users to independently navigate through the environment by selecting and displaying a sequence of images from the cameras, thereby simulating movement along different paths.

3. Grounds for Unpatentability

Ground 1: Claims 54, 55, and 119 are obvious over Conley, Kellogg, and Moezzi-1.

  • Prior Art Relied Upon: Conley (Patent 7,843,497), Kellogg (a 1993 MIT thesis titled "Visual Memory"), and Moezzi-1 (Patent 5,745,126).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the prior art combination taught all limitations of the challenged claims. Conley was asserted to disclose the core telepresence system, including a method and system for capturing images of an environment from an array of cameras and providing them in sequence to simulate motion. Petitioner emphasized that Conley taught a camera array with multiple series of cameras defining different paths with progressively different perspectives—the very features the patent owner argued distinguished the invention during prosecution. The remaining limitations related to multi-user functionality were allegedly supplied by Kellogg and Moezzi-1. Kellogg was cited for its teaching of a "visual memory" (a video database) with concurrency control that supports multiple, simultaneous users accessing data. Moezzi-1 was cited for its disclosure of a system where "many simultaneous remote viewers" can independently and interactively navigate through different views of a remote environment.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine the references to improve upon Conley's single-user system. A POSITA would have recognized the clear advantage of incorporating the established multi-user database and access technologies taught by Kellogg and Moezzi-1 into the telepresence system of Conley. This combination would predictably result in a system that allows multiple users to experience the simulated environment simultaneously and independently, a desirable and well-understood enhancement in the field. The combination was presented as augmenting Conley's video storage with the known concurrency and multi-user features of Kellogg and Moezzi-1.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in making the combination. The proposed modification involved substituting or augmenting Conley's video storage component with the known multi-user visual database taught by Kellogg. This was characterized as a straightforward integration of known components to achieve a predictable result—enabling multi-user access—rather than an inventive leap. The combination required applying conventional database technology to a known type of imaging system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv by noting that the parallel district court litigation had no trial date or case schedule set beyond claim construction at the time of filing. This lack of schedule progress was presented as a factor weighing heavily against denying institution, as it minimized concerns about inefficiency and overlap between the two proceedings.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 54, 55, and 119 of the ’226 patent as unpatentable under 35 U.S.C. §103.