LG Electronics Inc v. Maxell Ltd

1. Case Identification

• Case #: IPR2025-00392
• Patent #: 8,339,493
• Filed: December 31, 2024
• Petitioner(s): LG Electronics, Inc. and LG Electronics USA, Inc.
• Patent Owner(s): Maxell, Ltd.
• Challenged Claims: 5-14

2. Patent Overview

• Title: ELECTRIC CAMERA
• Brief Description: The ’493 patent describes an electric camera with an image sensor that operates in different modes, including a static image mode and a moving video mode. The camera’s signal processing unit generates image signals by using different methods of mixing or culling vertical pixel lines from the sensor depending on the selected mode of operation (e.g., recording a static image, monitoring in static mode, or recording a moving video).

3. Grounds for Unpatentability

Ground 1: Claims 5-14 are obvious over Misawa ’482 in view of Parulski

• Prior Art Relied Upon: Misawa ’482 (Patent 5,444,482) and Parulski (Patent 6,292,218).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Misawa ’482 discloses a digital camera with distinct still picture and movie picture modes. While Misawa ’482 teaches using all image data for a still picture and a cropped portion for a movie, it lacks distinct processing for monitoring. Parulski was argued to supply this missing element by teaching a camera with a motion/preview mode that uses a line-skipping process to generate a lower-resolution image for display on an LCD. The combination allegedly renders claim 5 obvious by providing three distinct processing methods: using all pixel lines for static recording (Misawa ’482), using a first line-skipping interval for monitoring a static image (Parulski), and using a second, different interval for recording a moving video (modifying Misawa ’482’s movie mode with Parulski’s line-skipping).
  • Motivation to Combine: A POSITA would combine the references to add a preview LCD and efficient line-skipping capability (from Parulski) to Misawa ’482’s camera. This would improve user experience by providing a live preview, reduce processing requirements, and enable rapid image processing.
  • Expectation of Success: Petitioner asserted a reasonable expectation of success because both references describe conventional digital cameras based on CCD image sensors, making the integration of their respective features straightforward and predictable.

Ground 2: Claims 5, 7-10, and 12-14 are obvious over Kurashige in view of Parulski

• Prior Art Relied Upon: Kurashige (1997 IEEE publication) and Parulski (Patent 6,292,218).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Kurashige teaches a digital camera with a CCD image sensor, an LCD for monitoring, a JPEG still picture mode, and an MPEG moving picture mode. Kurashige’s motion mode uses a "line-mixed readout" to produce a lower-resolution image (352x240) from a higher-resolution sensor (720x480). Parulski was argued to provide more advanced and varied line-skipping techniques. Petitioner argued a POSITA would apply Parulski's line-skipping methods to Kurashige's system to create distinct processing for monitoring a still image (first culling interval) and recording a moving picture (second culling interval), thereby meeting the limitations of claim 5.
  • Motivation to Combine: A POSITA would be motivated to incorporate Parulski’s line-skipping techniques into Kurashige’s camera to reduce geometric distortions when adapting a high-resolution sensor output to lower-resolution displays and video formats. This modification would preserve visual information more effectively than Kurashige’s simple "line-mixed" approach.
  • Expectation of Success: Success would be expected, as both references relate to CCD-based digital cameras. Applying Parulski's well-understood line-skipping processing to Kurashige's camera system was presented as a predictable design improvement.

Ground 3: Claims 5, 7-10, and 12-14 are obvious over Juen in view of Misawa ’607

• Prior Art Relied Upon: Juen (Patent 7,903,162) and Misawa ’607 (Patent 6,700,607).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Juen discloses an electronic camera with separate moving and still image modes, an image sensor with a pixel count larger than the display, and a "pixel density conversion means" to adapt the image for display. Misawa ’607 was argued to teach specific and varied line-skipping methods for reducing the number of lines read from an image sensor (e.g., read 1/2, 1/4, or 1/8 of the lines) to display images at a high refresh rate. The combination of Juen's camera architecture with Misawa ’607's specific line-skipping methods was argued to render the claims obvious by providing different culling intervals for monitoring (e.g., 1/4 line-skipping) and movie recording (e.g., 1/2 line-skipping).
  • Motivation to Combine: A POSITA would implement Misawa ’607's efficient line-skipping processes as the "pixel density conversion means" in Juen’s camera. This would increase image refresh rates on the display, decrease power consumption, and improve processing speed for both monitoring and recording video.
  • Expectation of Success: This combination would have a high expectation of success, as it involves applying a known, advantageous data-reduction technique (Misawa ’607) to a standard digital camera architecture (Juen) to achieve predictable benefits.

4. Arguments Regarding Discretionary Denial

• Fintiv Factors: Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigation is in its early stages with no trial date set. The Board’s Final Written Decision (FWD) would issue approximately 1.5 years before the projected trial date. Furthermore, the petition challenges claims beyond those asserted in the litigation.
• General Plastic Factors: Petitioner contended that denial under General Plastic is unwarranted. Although the ’493 patent was the subject of prior IPRs, the Petitioner here was not a party or real-party-in-interest to those prior proceedings and has no "significant relationship" with the prior petitioners.
• §325(d) / Advanced Bionics: Petitioner argued that denial under §325(d) is improper because the petition raises new issues. The Kurashige reference has never been considered by the USPTO. While other references were previously presented, they are used here in new combinations and arguments that were not previously considered on their merits by the Board.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 5-14 of the ’493 patent as unpatentable.