Amazon.com Inc v. Nokia Technologies Oy

1. Case Identification

• Case #: IPR2024-00627
• Patent #: 11,805,267
• Filed: March 15, 2024
• Petitioner(s): Amazon.com, Inc., Amazon.com Services LLC
• Patent Owner(s): Nokia Technologies OY
• Challenged Claims: 19-36

2. Patent Overview

• Title: Utilizing Motion Prediction in Video Coding
• Brief Description: The ’267 patent discloses methods for reducing rounding errors in bi-directional video prediction. The invention maintains prediction signals at a higher precision during intermediate calculations and only rounds the combined prediction down to a lower precision after the signals have been combined.

3. Grounds for Unpatentability

Ground 1: Claims 19-36 are obvious over Walker

• Prior Art Relied Upon: Walker (Application # 2005/0281334).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Walker teaches all limitations of the challenged claims. Walker discloses weighted prediction methods for H.264 video decoding where pixel values have a first precision (e.g., 8 bits). Walker’s disclosed decoding formula and accompanying tables explicitly show intermediate prediction values being calculated and stored with a second, higher precision (e.g., 17 bits). This combined prediction, which is based on first and second predictions, is then decreased in precision by a right bit-shift operation to reconstruct the final pixel block. This process directly maps to the steps recited in independent claims 19, 25, and 31. Petitioner further contended that Walker’s teachings on sub-pixel interpolation, rounding offsets, and bit-shifting for multiplication/division render the dependent claims obvious.

Ground 2: Claims 19-36 are obvious over Karczewicz-I in view of Karczewicz-II

• Prior Art Relied Upon: Karczewicz-I (Application # 2011/0007799) and Karczewicz-II (Application # 2009/0257499).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Karczewicz-I teaches a standard bi-directional prediction method for H.264 video decoding, which averages two predictions from different reference blocks. This reference provides the foundational framework but involves rounding operations that can introduce inaccuracies. Karczewicz-II addresses this known problem by teaching an improved method for averaging interpolated pixel values. Specifically, Karczewicz-II teaches keeping intermediate values at the "highest possible precision" by using non-rounded, higher-bit-depth values (e.g., 15-bit half-pixel predictions) and delaying any shifting or rounding until the final step of the interpolation process. The combination, therefore, discloses determining first and second predictions from reference blocks, where the predictions have a higher precision (e.g., 13 or 15 bits) than the initial pixels (8 bits), combining them, and then decreasing the precision of the combined result via a right bit-shift.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because they are from the same inventors, address complementary aspects of H.264 video coding, and share compatible architectures. Karczewicz-II provides a known technique—delaying rounding to improve accuracy—to solve a known problem—rounding errors—inherent in the bi-prediction averaging process taught by Karczewicz-I. The art provided express motivation to use higher-precision intermediate values to improve motion compensation and interpolation accuracy.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the teachings. The combination involves applying the straightforward mathematical and logical operations (e.g., addition, bit-shifting) from Karczewicz-II to the corresponding calculations in Karczewicz-I, which would predictably result in improved prediction accuracy by reducing compounded rounding errors.

4. Key Claim Construction Positions

• "precision": Petitioner argued that a POSITA would have understood this term to mean "a number of bits needed to represent possible values." This construction is supported by the patent specification, the prosecution history, and is explicitly recited in dependent claims 24, 30, and 36. This construction is central to the obviousness arguments, as the prior art discloses changing the number of bits used for intermediate versus final values.

5. Arguments Regarding Discretionary Denial

• Fintiv Denial: Petitioner argued discretionary denial under Fintiv is not warranted. The ’267 patent was asserted in a parallel ITC proceeding, which subjects related district court proceedings to a mandatory stay. Petitioner cited a PTAB memorandum stating the Board will not discretionarily deny petitions based on applying Fintiv to a parallel ITC proceeding.
• §325(d) Denial: Petitioner contended that denial under 35 U.S.C. §325(d) is inappropriate. The primary references for the grounds, Walker and Karczewicz-I, were not cited or considered during prosecution. Although Karczewicz-II was cited in an Information Disclosure Statement (IDS), it was submitted along with 76 other references and was not subject to any substantive analysis by the Examiner.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 19-36 of the ’267 patent as unpatentable.