PTAB

IPR2024-00062

Samsung Electronics Co Ltd v. Advanced Coding Technologies LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Video-Emphasis Encoding Apparatus and Decoding Apparatus and Method of Video-Emphasis Encoding and Decoding
  • Brief Description: The ’128 patent relates to video encoding and decoding systems that apply emphasis processing to an input video signal. The disclosed invention sets an emphasis level based on factors such as quantization parameters used for encoding or the level of enhancement processing already applied to the input signal.

3. Grounds for Unpatentability

Ground 1A: Claims 1-6 and 8 are obvious over Fukuda

  • Prior Art Relied Upon: Fukuda (Patent 5,491,514)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fukuda’s "coding and decoding apparatus" teaches all limitations of the challenged claims. Fukuda disclosed setting an emphasis level based on detected picture states (e.g., signal amplitude, activity, motion) and encoding conditions (e.g., compression rate, coding distortion), thereby teaching the "emphasis-level setter" of independent claims 1 and 4. Fukuda’s emphasis circuit and coding circuit were mapped to the claimed "emphasizer" and "encoder" elements, respectively. For the "multiplexer" limitation, Petitioner contended that while Fukuda did not explicitly name a multiplexer, it taught transmitting mode signals "together with coded image data." A person of ordinary skill in the art (POSITA) would have found it obvious to use a well-known multiplexer to achieve this, as it was a common and predictable design choice. The corresponding decoding elements of claims 5 and 8 were also allegedly taught by Fukuda’s complementary decoding apparatus.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing a multiplexer in Fukuda's system, as multiplexing was a mature and widely understood technique for combining data streams with predictable results.

Ground 1B: Claims 1-4 are obvious over Fukuda in view of Fujikawa

  • Prior Art Relied Upon: Fukuda (Patent 5,491,514), Fujikawa (Patent 5,241,387)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground reinforced the arguments of Ground 1A by using Fujikawa to explicitly teach concepts that were argued as obvious general knowledge in the first ground. Fujikawa explicitly taught multiplexing data necessary for decoding (including quantization step size values) with the encoded video signal, directly corroborating the obviousness of the "multiplexer" limitation in Fukuda. Furthermore, Fujikawa taught a noise reduction filter that applies high-frequency emphasis based on the degree of contrast between regions, providing an additional, explicit teaching for setting an emphasis level based on a "picture state detected from the input video signal."
    • Motivation to Combine: A POSITA, seeking to implement Fukuda’s teaching of transmitting control data with video data, would have been motivated to consult a reference like Fujikawa, which explicitly described multiplexing as a method to accomplish this. Additionally, a POSITA would combine the references to improve Fukuda’s system by incorporating Fujikawa's advanced noise reduction and picture quality enhancement techniques, which were known problems in the field.
    • Expectation of Success: The combination involved applying known techniques (multiplexing, noise reduction) to a known base system (Fukuda) to achieve predictable improvements in data transmission efficiency and image quality.

Ground 2: Claims 1-6 and 8 are obvious over Atsumi

  • Prior Art Relied Upon: Atsumi (Patent 6,801,665)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Atsumi’s method for encoding image data with emphasis on a specified "region of interest" (ROI) taught all challenged claim limitations. Atsumi’s "ROI coefficient scaling step" was mapped to the "emphasis-level setter," as it sets the emphasis level based on "encoding conditions" (quantization indices) and a "picture state" (the identified ROI). This same step was also mapped to the "emphasizer." Atsumi’s "entropy coding" step, which forms the encoded data stream, was identified as the claimed "encoder." Petitioner argued that Atsumi’s "transmitter," which appends header bits containing ROI information (emphasis data) to the data bits to form a single bitstream, inherently performed the function of the claimed "multiplexer." The decoding claims were similarly mapped to Atsumi’s corresponding decompression method, where a "deemphasis-level setter" uses the received ROI data to de-scale the coefficients.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) and the Fintiv factors would be inappropriate. The core reason provided was that Petitioner has presented a Sotera stipulation, agreeing not to pursue in a parallel district court litigation the same grounds raised in the petition. Under USPTO guidance, this stipulation is intended to weigh strongly against discretionary denial.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 8 of Patent 6,845,128 as unpatentable.