PTAB

IPR2024-00848

Amazon.com Inc v. Nokia Technologies Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Video Coding
  • Brief Description: The ’808 patent discloses a video encoding method that redefines the "skip mode" for coding macroblocks. The invention allows a macroblock in skip mode to be associated with either a zero motion vector (copied directly from a reference frame) or a predicted non-zero motion vector derived from the motion of neighboring, previously-coded blocks.

3. Grounds for Unpatentability

Ground 1: Obviousness over Karczewicz - Claims 10-11, 15-16, 20-22, 44, 47-49, 51-54, 58-60, and 62-64 are obvious over Karczewicz.

  • Prior Art Relied Upon: Karczewicz (WO 01/11891).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Karczewicz taught an apparatus for video encoding with multiple coding modes, the combination of which renders the challenged claims obvious. Specifically, Karczewicz disclosed a mode using a zero motion vector (ZMV) where a segment is copied from a reference frame, and a separate mode where a segment’s motion vector is predicted from a neighboring segment (a predicted non-zero motion vector, or PNZMV). Petitioner asserted that Karczewicz’s “Motion Field Coder (MFC)” functions as the claimed "coding controller" by selecting the most efficient mode based on rate-distortion analysis. The selection between using a ZMV or a PNZMV is therefore based on the motion characteristics of neighboring segments, meeting the core limitations of independent claims 10 and 16.
    • Motivation to Combine (N/A - Single Reference): While not a combination, Petitioner argued a person of ordinary skill in the art (POSITA) would have understood that Karczewicz’s ZMV and PNZMV prediction modes represent two functionalities that could be grouped under a single redefined "skip coding mode" as claimed in the ’808 patent. The choice between these functionalities is an obvious design decision based on coding efficiency, which Karczewicz explicitly taught. An indicator bit (the "MCI" bit) in Karczewicz was alleged to signal when a segment is assigned to one of these modes, thus providing the claimed "indication of the skip coding mode."

Ground 2: Obviousness over Frojdh in view of AAPA - Claims 10-11, 16, 21-22, 44, 47-49, 58-60, and 64 are obvious over Frojdh in view of AAPA.

  • Prior Art Relied Upon: Frojdh (Application # 2003/0123738) and AAPA (Admitted Art Prior Art from Patent 7,532,808).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Frojdh taught an improved Global Motion Compensation (GMC) technique for video compression that disclosed the core functionality of the claimed invention. Frojdh’s system included a "COPY" (or SKIP) mode that used a ZMV and an "Implicit GMC" (IGMC) mode that used a PNZMV predicted from neighboring blocks. Petitioner argued this combination of modes in Frojdh taught the claimed skip mode that assigns either a ZMV or PNZMV based on neighbor motion. While Frojdh described the method, it lacked a detailed encoder/decoder structure. AAPA, which is admitted prior art from the ’808 patent itself, provided the standard, well-known encoder/decoder architecture (e.g., control manager, motion estimation block) to implement Frojdh’s method.
    • Motivation to Combine: A POSITA would combine Frojdh’s advanced coding method with AAPA’s generic encoder/decoder architecture to create a functional system. Frojdh provided the "what" (the improved skip mode concept), while AAPA provided the "how" (the standard functional blocks to build it), representing a straightforward implementation of a known method using known components.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved using a standard, exemplary encoder (AAPA) to implement a compatible video coding technique (Frojdh). The result would be predictable: an operational video codec with the benefits of Frojdh's improved skip mode.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 2B) based on Frojdh, AAPA, and H.263. This ground argued that the H.263 video coding standard provided specific, well-known median-based prediction rules for deriving motion vectors from neighboring blocks, supplying details for the higher-level prediction method described in Frojdh.

4. Key Claim Construction Positions

  • "skip coding mode": A central issue was whether the term "skip coding mode" permits the inclusion of residual information (i.e., prediction error).
    • Petitioner's Position: Petitioner argued the term should be construed to allow for residual information to be provided. This construction was supported by the doctrine of claim differentiation, as dependent claims 49 and 60 explicitly recited "wherein no residual information is provided," implying the base independent claims (10 and 16) did not have this limitation.
    • Overall Argument: Petitioner contended that the challenged claims are invalid regardless of which construction is adopted. Ground 1 was argued to demonstrate unpatentability under Petitioner's broader construction, while Ground 2 was argued to demonstrate unpatentability under at least the Patent Owner's narrower construction (precluding residual information).

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 10-11, 15-16, 20-22, 44, 47-49, 51-54, 58-60, and 62-64 of the ’808 patent as unpatentable.