PTAB
IPR2023-00910
Samsung Electronics Co Ltd v. Advanced Coding Technologies LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2023-00910
- Patent #: 9,445,041
- Filed: May 12, 2023
- Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
- Challenged Claims: 1-6
2. Patent Overview
- Title: Moving Image Data Processing Apparatus and Moving Image Data Processing Method
- Brief Description: The ’041 patent discloses techniques for processing moving image data (video) to enable playback at an arbitrary frame rate and speed. The system accepts video generated at various input frame rates, allows for specification of an output frame rate and playback speed, and converts the video data accordingly using methods like interpolation and decimation.
3. Grounds for Unpatentability
Ground 1A: Obviousness over Morikawa - Claims 1-2, 4, and 6 are obvious over Morikawa
- Prior Art Relied Upon: Morikawa (Application # 2010/0226622).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Morikawa disclosed all limitations of the challenged claims. Morikawa described a video playing apparatus that inputs video composed of portions recorded at different frame rates (e.g., a "first portion" at an ordinary rate and a "second portion" at a higher rate). This meets the limitation of an input unit configured for video data with different frame rates. Morikawa’s "rate analysis unit" analyzed these input frame rates from metadata and specified a "predetermined playback frame rate" based on an external display device’s capabilities (e.g., 60 Hz), satisfying the requirements for both an input and output frame rate specification unit. To maintain a "normal speed" playback, Morikawa’s image processing unit performed a "frame decimating process" on the high frame-rate portions, which Petitioner asserted meets the frame rate conversion limitation.
- Motivation to Combine: Not applicable for a single-reference ground.
- Expectation of Success: Not applicable for a single-reference ground.
- Key Aspects: Petitioner contended that Morikawa’s "rate analysis unit" performs the functions of both the claimed input and output frame rate specification units, and argued that implementing these functions in one or two separate units would be an obvious design choice.
Ground 1B: Obviousness over Morikawa and Takabe - Claim 3 is obvious over Morikawa in view of Takabe
- Prior Art Relied Upon: Morikawa (Application # 2010/0226622), Takabe (WO 2004/090703).
- Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that claim 3, which recites a display unit and an operating unit that displays parameters in a "circular ring shape," is obvious over the combination. Morikawa provided the base video processing system as described in Ground 1A. Takabe taught a user interface for a digital camera that displayed and allowed selection of various settings (e.g., shutter speed) using a graphical "circular ring shape" on its display panel. Petitioner argued that applying Takabe's intuitive circular interface to Morikawa's system for selecting parameters like frame rate or playback speed would render claim 3 obvious.
- Motivation to Combine: A POSITA would combine Takabe’s user interface with Morikawa’s system to gain the benefit of an "easy to understand" interface for selecting video parameters. This modification was presented as the application of a known solution (an improved graphical user interface) to a similar system to yield predictable results.
- Expectation of Success: Petitioner asserted a high expectation of success, as Takabe described its interface working within an imaging device, making its application to Morikawa's video processing apparatus straightforward.
Ground 2A: Obviousness over Suzuki - Claims 1 and 6 are obvious over Suzuki
Prior Art Relied Upon: Suzuki (Application # 2012/0314967).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Suzuki’s imaging apparatus disclosed all limitations. Suzuki described capturing moving image data at different frame rates (e.g., 60fps and 240fps). The system recorded information on the input frame rates and allowed for setting a reproduction speed ("M") and an output frame rate (e.g., 60fps). Critically, Suzuki taught a frame rate conversion process where a control unit sets the "interval of frames to be displayed" using the formula FR/60xM, where FR is the input frame rate. This formula directly changes the frame rate of different video segments based on their respective input frame rates, the specified output frame rate, and the selected playback speed, thus mapping to the core limitations of the independent claims.
- Motivation to Combine: Not applicable for a single-reference ground.
- Expectation of Success: Not applicable for a single-reference ground.
Additional Grounds: Petitioner asserted additional obviousness challenges based on Morikawa in view of Walpole (for claim 5), and Suzuki in view of Takabe (claim 3), Sekiguchi (claim 4), and Walpole (claim 5), relying on similar motivations to add user interface improvements or adapt playback to device and network capabilities.
4. Arguments Regarding Discretionary Denial
- Petitioner argued that discretionary denial under §314(a) and Fintiv is inappropriate. The petition was filed with a motion for joinder to a co-pending IPR (IPR2022-01548) where the Board had already found a reasonable likelihood that the claims of the ’041 patent are unpatentable. Petitioner contended that no trial date was set in the parallel district court litigation and the Final Written Decision in the existing IPR was due well before any potential trial. Denying institution and joinder would risk leaving a likely invalid patent in place should the parties in the first IPR settle.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-6 of the ’041 patent as unpatentable.
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