Samsung Electronics Co Ltd v. Advanced Coding Technologies LLC

1. Case Identification

• Case #: IPR2024-00245
• Patent #: 8,139,150
• Filed: December 8, 2023
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Advanced Coding Technologies LLC
• Challenged Claims: 1-4

2. Patent Overview

• Title: Method and Apparatus for Encoding and Decoding Multi-View Video Signal, and Related Computer Programs
• Brief Description: The ’150 patent describes techniques for processing a multi-view video signal that includes picture signals from different viewpoints. The system designates one viewpoint as a "base viewpoint," which is encoded independently, and uses coded information representing a "desired delay time" to control the start of decoding for the other non-base viewpoints relative to the base viewpoint.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chen-736 in view of Chen-051 - Claims 2 and 3

• Prior Art Relied Upon: Chen-736 (Patent 5,886,736) and Chen-051 (Application # 2003/0138051).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Chen-736, a patent from the same inventor filed a decade before the ’150 patent’s priority date, discloses the core invention. Chen-736 teaches a stereoscopic (two-view) video system with a "base layer" (base viewpoint) and an "enhancement layer" (non-base viewpoint). It explicitly teaches using Decode Time Stamps (DTS) to synchronize the layers, including calculating and using DTS values for the enhancement layer to delay its decoding relative to the base layer. This delay, represented by the DTS values, constitutes the claimed "coded information representing a desired delay time." Chen-051 teaches improving the efficiency of transmitting such timestamp information by encoding differential values (e.g., the delay itself) rather than absolute timestamps, which required a large number of bits.
  • Motivation to Combine: A POSITA would combine Chen-736 and Chen-051 to solve the known problem of inefficiency in transmitting absolute DTS values, as noted in Chen-051. Applying Chen-051’s differential coding to Chen-736’s system would be a predictable solution to compress the video bitstream. The teachings are highly compatible as both relate to MPEG-2 video standards and were proposed by the same inventor.
  • Expectation of Success: A POSITA would have a high expectation of success, as the combination involves applying a known data compression technique (differential coding of timestamps) to a standard video decoding system to achieve the predictable result of improved efficiency.

Ground 2: Obviousness over Chen-736 in view of the H.262 Specification - Claim 1

• Prior Art Relied Upon: Chen-736 (Patent 5,886,736) and the H.262 Specification (an ITU-T Recommendation, Feb. 2000).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses the "means-plus-function" limitations of apparatus claim 1. Petitioner asserted that Chen-736 discloses the overall system, including a "lower decoder" and an "enhancement decoder" that perform the functions recited in the claim. The H.262 Specification, which defines the MPEG-2 standard that Chen-736 is based on, provides the specific algorithmic structures for the claimed "means." For example, H.262 details the video decoding process, including motion-compensated prediction, inverse quantization, and inverse orthogonal transforms, which correspond to the functions of the "second means" (decoding the base viewpoint) and "third means" (decoding the non-base viewpoint). The "first means" and "fourth means" (recovering and applying the delay) are met by a processor in Chen-736’s decoder that parses DTS values and uses them to control decoding timing, a standard operation detailed in H.262.
  • Motivation to Combine: A POSITA implementing Chen-736’s system, which explicitly references the MPEG-2 standard, would have been motivated to consult the H.262 Specification for standard-compliant implementation details. The combination is a straightforward application of a technical standard to a system designed to operate under that standard.
  • Expectation of Success: Success would be expected, as the H.262 Specification is a foundational document providing the necessary, well-understood algorithms for implementing an MPEG-2 compliant decoder like the one described in Chen-736.

Ground 3: Obviousness over Chen-736 in view of Tseng - Claims 2 and 3

• Prior Art Relied Upon: Chen-736 (Patent 5,886,736) and Tseng (an IEEE publication, Aug. 1996).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addresses the potential interpretation that "multi-view" requires more than two viewpoints. Chen-736 discloses a two-view (stereoscopic) system. Tseng, an academic paper, explicitly teaches extending the two-view MPEG-2 framework to a "multiviewpoint video" system with more than two views (e.g., a central view and four additional views). Tseng recognizes that decoding non-central views may require a delay relative to the central view.
  • Motivation to Combine: A POSITA would combine the teachings to extend Chen-736's two-view decoding delay system to a system with more than two views, as suggested by Tseng. Tseng explicitly describes its work as a "novel multiview codec... to complement the MPEG-2 standard," the same standard used by Chen-736. The motivation was to enhance 3-D video systems, a known area of development at the time.
  • Expectation of Success: A POSITA would have expected success in applying the delay logic of Chen-736 to each of the additional non-base viewpoints described in Tseng, as it is a mere scaling of a known technique to additional data streams within a compatible framework.

• Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Chen-736, Chen-051, Tseng, and the H.262 Specification to address claims 1 and 4, relying on similar motivations and art mappings.

4. Key Claim Construction Positions

• "coded multi-view video signal" (claims 1-4): Petitioner argued this term should be construed to encompass signals for two or more viewpoints, including stereoscopic video which has only one base and one non-base viewpoint. This construction is supported by the patent's specification, which extensively discusses stereoscopic video as an example embodiment.
• "means-plus-function" Elements (claim 1): Petitioner argued that the four "means for" limitations in claim 1 are means-plus-function elements under §112, ¶6. The corresponding structure disclosed in the specification is a general-purpose processor configured by software to perform the claimed functions (e.g., parsing bitstreams, performing motion compensation, delaying decoding based on timing data). This construction is critical for mapping prior art like the H.262 Specification, which provides the specific algorithms that would configure such a processor.

5. Arguments Regarding Discretionary Denial

• §325(d) - Same or Substantially Same Art: Petitioner argued that discretionary denial is unwarranted because the prior art references and combinations asserted in the petition (Chen-736, Chen-051, Tseng, H.262) were never considered during the original prosecution. Therefore, the challenge is not the same as, or substantially similar to, arguments previously presented to the Office.
• §314(a) - Fintiv Factors: Petitioner argued that denial under Fintiv is not merited because it has submitted a Sotera stipulation, agreeing not to pursue the same invalidity grounds in the parallel district court litigation. Petitioner cited USPTO guidance indicating that the PTAB will not discretionarily deny institution in view of such a stipulation.

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-4 of Patent 8,139,150 as unpatentable.