PTAB

IPR2025-00444

LG Electronics Inc v. Maxell Ltd

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petition

1. Case Identification

2. Patent Overview

  • Title: ELECTRIC CAMERA
  • Brief Description: The ’729 patent discloses an electric camera that uses different sets of pixels from an image sensor for different operational modes. It describes forming image signals using a first set of pixels for monitoring in a static image mode, all effective pixels for recording in the static image mode, and a second, smaller set of pixels for recording in a moving video mode to enable electronic image stabilization.

3. Grounds for Unpatentability

Ground 1: Obviousness over Misawa and Parulski - Claims 1-4

  • Prior Art Relied Upon: Misawa (Patent 5,444,482) and Parulski (Patent 6,292,218).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Misawa taught a digital camera with distinct "still picture" and "movie picture" modes. In its movie mode, Misawa used a smaller portion of the image sensor's pixels to enable electronic image stabilization by shifting the readout area. In its still mode, it used the entire sensor area. Petitioner contended that Parulski supplied the missing "monitoring" operation for the static image mode, teaching a "motion preview mode" that used a line-skipping technique (a first effective set of pixels) to display a preview image on an LCD screen before capturing a full-resolution still image. The combination of Misawa's base camera architecture and Parulski's preview functionality allegedly rendered all limitations of claims 1-4 obvious.
    • Motivation to Combine: A POSITA would combine Parulski's teachings with Misawa's camera to add the well-understood benefit of an LCD preview function. This would allow a user to compose an image on the camera's screen before capture, improving usability and the quality of captured images. Parulski’s user interface, including zoom and capture buttons, provided a known solution for controlling these functions.
    • Expectation of Success: A POSITA would have a high expectation of success, as both references pertained to digital cameras and integrating a preview mode into a camera was a predictable and common design choice.

Ground 2: Obviousness over Kawahara, Misawa, and Parulski - Claims 1-4

  • Prior Art Relied Upon: Kawahara (Patent 6,963,361), Misawa (Patent 5,444,482), and Parulski (Patent 6,292,218).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Kawahara taught a camera with selectable still and moving image modes that performed image stabilization by shifting an extraction frame (a portion of the sensor's pixels). Kawahara acknowledged that this technique could deteriorate resolution in still images. Petitioner argued Misawa was relevant for its teaching of performing blur compensation only when recording moving images, thereby preserving full resolution for still images. Parulski was added for the same reasons as in Ground 1: to provide a "monitoring" or preview mode using a subset of pixels on an integrated LCD.
    • Motivation to Combine: A POSITA would modify Kawahara’s camera based on Misawa’s teachings to solve the resolution-loss problem that Kawahara itself identified. Applying stabilization only during moving image recording (as taught by Misawa) was an obvious solution to preserve still image quality while reducing processing burden. A POSITA would then add Parulski's LCD preview to Kawahara’s camera to provide the known benefits of image composition prior to capture.
    • Expectation of Success: The combination was argued to be predictable, as it involved applying a known solution (from Misawa) to a known problem (in Kawahara) and adding a standard feature (Parulski's preview mode).

Ground 3: Obviousness over Tomita, Kawahara, and Parulski - Claims 1-4

  • Prior Art Relied Upon: Tomita (Patent 6,690,881), Kawahara (Patent 6,963,361), and Parulski (Patent 6,292,218).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Tomita taught a camera with the core claimed functionality: a monitoring mode ("E-to-E mode") using a thinned-out set of pixels, a still picture mode using all pixels, and a moving picture mode using a cropped portion of pixels. Petitioner contended that Tomita lacked an explicit teaching of image stabilization. Kawahara was introduced to supply this missing element, as it taught a well-known method of electronic image stabilization by shifting a readout window. Parulski was added to provide a more advanced user interface for selecting between Tomita's various modes.
    • Motivation to Combine: A POSITA would combine Kawahara's known image stabilization technique with Tomita's camera to improve the quality of its moving picture mode, a standard design goal. Furthermore, a POSITA would be motivated to incorporate Parulski's on-screen menu-based user interface as an alternative to Tomita's physical buttons, providing a simple and known way to improve user experience when selecting between multiple camera modes.
    • Expectation of Success: Petitioner argued success would be highly predictable, as this ground involved adding a conventional feature (Kawahara's stabilization) and a simple user interface improvement (from Parulski) to an existing camera design (Tomita).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate under 35 U.S.C. §§ 314(a) and 325(d).
  • Fintiv Factors: Petitioner contended that the parallel district court litigation was in its earliest stages, with no trial date set and claim construction not yet underway. The Board's Final Written Decision (FWD) would likely issue approximately 1.5 years before any projected trial date, favoring institution.
  • General Plastic/§325(d): Petitioner argued that a prior IPR filed by a third party (ZTE Corporation) should not bar institution because Petitioner was not the same party, a real party-in-interest, or in privity with the prior petitioner.
  • Advanced Bionics/§325(d): Petitioner asserted that the specific prior art references and combinations presented in this petition were not previously considered by the Patent Office during prosecution or by the Board in the prior IPR, making the arguments new and not cumulative.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4 of the ’729 patent as unpatentable under 35 U.S.C. §103.