PTAB
IPR2024-01423
Aputure Imaging Industries Co Ltd v. Rotolight Ltd
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2024-01423
- Patent #: 10,203,101
- Filed: September 16, 2024
- Petitioner(s): Aputure Imaging Industries Co., Ltd.
- Patent Owner(s): Rotolight Limited
- Challenged Claims: 1-21
2. Patent Overview
- Title: Method and System for Producing Lighting Effects with Rolling Shutter Compensation
- Brief Description: The ’101 patent discloses a method, controller, and computer program for producing user-customizable lighting effects. The system calculates time-varying lighting values based on user input related to camera parameters (e.g., frame rate, shutter speed) to compensate for visual artifacts produced by a camera’s rolling shutter.
3. Grounds for Unpatentability
Ground 1: Obviousness over Mueller and Edwards - Claims 1-21 are obvious over Mueller in view of Edwards.
- Prior Art Relied Upon: Mueller (Application # 2005/0275626) and Edwards (Patent 9,743,010).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Mueller disclosed a lighting control system with a processor capable of generating a wide range of user-customizable, time-varying lighting effects based on user-selectable parameters. However, Mueller did not explicitly teach compensating for rolling shutter artifacts. Edwards allegedly supplied this missing element by teaching a system that synchronizes LED lighting with a camera’s shutter, specifically timing lighting changes to occur during the closed shutter period to prevent visual artifacts.
- Motivation to Combine: Petitioner contended that Mueller and Edwards were in the same field of entertainment lighting systems. A person of ordinary skill in the art (POSITA), aware of the well-known problem of flicker and rolling shutter artifacts in video recording, would combine Edwards’s synchronization solution with Mueller’s customizable effects generator to create a more robust and commercially desirable lighting system.
- Expectation of Success: A POSITA would expect success because the combination involved applying a known solution (shutter synchronization) to a known problem (artifacts) within a compatible system (programmable lighting controller), requiring only conventional software modifications.
Ground 2: Anticipation and Obviousness over Astera - Claims 1, 2, 5-17, and 21 are anticipated by or obvious over Astera.
- Prior Art Relied Upon: Astera (a user manual for the publicly available AX10 lighting device).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that the Astera manual, which described the functionality of the commercial AX10 light, disclosed every limitation of the challenged claims. The AX10 system provided an "effect simulator" (via an on-board control panel or a mobile app) that allowed users to select and customize lighting effects like fire, strobes, and color fades. Crucially, Astera taught compensating for camera artifacts through an "Anti-Flicker" setting. This feature allowed a user to input a camera’s frame rate, and the system would then calculate and adjust the light’s PWM refresh frequency to avoid flicker, which Petitioner argued was a form of rolling shutter artifact. The calculated lighting values were then output to the AX10 lighting device to simulate the compensated effect.
Ground 3: Obviousness over Astera and Edwards - Claims 3, 4, and 18-20 are obvious over Astera in view of Edwards.
- Prior Art Relied Upon: Astera (AX10 user manual) and Edwards (Patent 9,743,010).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that while Astera taught compensating for camera artifacts by adjusting PWM refresh frequency based on frame rate, Edwards disclosed additional and more direct methods for preventing artifacts. Specifically, Edwards taught calculating lighting values to vary at a rate equivalent to the camera's frame rate and matching the light's minimum pulse width to the camera's shutter speed. This ensured that lighting transitions only occurred when the shutter was closed and that the frame was evenly illuminated.
- Motivation to Combine: A POSITA would combine Edwards’s teachings with Astera's system to provide additional, well-understood options for artifact compensation. Adding the ability to synchronize lighting changes directly with the shutter-closed period, as taught by Edwards, would be a predictable improvement to Astera’s existing anti-flicker feature, resulting in more reliable artifact prevention across different camera settings.
- Expectation of Success: The combination was argued to be predictable because Astera already provided a user interface for inputting camera parameters (frame rate). Adding further camera-related inputs like shutter speed to implement Edwards’s known synchronization techniques would have been a straightforward modification for a POSITA.
4. Arguments Regarding Discretionary Denial
- Petitioner argued that discretionary denial under Fintiv would be inappropriate. The parallel district court litigation was in its earliest stages, with only a complaint and amended complaint filed. No trial date was scheduled, and the average time to trial in the relevant venues far exceeded the statutory deadline for a Final Written Decision (FWD) in an inter partes review (IPR). Petitioner asserted that minimal resources had been invested in the litigation, and allowing the IPR to proceed would be the most efficient course for resolving the validity of the challenged claims.
5. Relief Requested
- Petitioner requested the institution of an IPR and the cancellation of claims 1-21 of the ’101 patent as unpatentable.
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