PTAB

IPR2025-00461

Samsung Electronics Co Ltd v. Optimum Imaging Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Digital Imaging System for Image Filtration
  • Brief Description: The ’805 patent discloses a digital imaging system, such as a digital camera, that performs in-camera correction of optical aberrations (e.g., vignetting) using a combination of hardware components like a lens, sensor, processors, and memory, managed by system software and a database.

3. Grounds for Unpatentability

Ground 1: Claims 9 and 24 are obvious over Niikawa in view of Enomoto

  • Prior Art Relied Upon: Niikawa (Application # 2002/0135688) and Enomoto (Patent 6,323,934).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Niikawa discloses a digital camera system with all the core components recited in the independent claims, including a lens, sensor, microprocessor, digital signal processor (or an obvious hardware equivalent), ASIC, software, database (correction tables in ROM), and memory. Niikawa’s system performs in-camera correction for a specific aberration known as "shading" or vignetting. Enomoto teaches an image processing apparatus that corrects for multiple types of aberrations (e.g., chromatic aberration, distortion, blurring) by storing corresponding lens characteristics and correction functions in a database.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Niikawa’s camera system with Enomoto’s teaching of correcting multiple aberration types to improve overall image quality. Both Niikawa and Enomoto explicitly state their purpose is to improve image quality, providing a clear reason to incorporate Enomoto’s more comprehensive correction capabilities into Niikawa’s foundational camera architecture.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, as combining known techniques to correct multiple, known types of aberrations was a straightforward extension of the art to achieve a more robust image correction system.

Ground 2: Claims 1-3 and 18-20 are obvious over Niikawa in view of Enomoto and Levien

  • Prior Art Relied Upon: Niikawa (Application # 2002/0135688), Enomoto (Patent 6,323,934), and Levien (Patent 5,524,162).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the combination of Niikawa and Enomoto by adding Levien. The challenged claims require applying a Fast Fourier Transform (FFT) to satisfy a user-specified "special effects function," such as a color-enhancing or soft-effect diffusion function. Petitioner asserted that while Niikawa and Enomoto provide the aberration-correcting camera system, Levien discloses using an FFT to control image blur and sharpening, which are types of special effects.
    • Motivation to Combine: A POSITA would be motivated to incorporate Levien’s FFT-based techniques into the Niikawa/Enomoto system to provide users with advanced, desirable special effects. Niikawa itself teaches a user-selectable mode for creating a blurred background effect. A POSITA would look to known, powerful algorithms like the FFT taught by Levien to implement such effects more effectively.
    • Expectation of Success: Success would be expected because using FFTs for image processing was a well-known and powerful technique. Implementing Levien's methods in the processor of the Niikawa/Enomoto camera would be a predictable application of a known algorithm to achieve a known result (image enhancement).

Ground 3: Claims 4-8 and 21-23 are obvious over Niikawa in view of Enomoto and Yamasaki

  • Prior Art Relied Upon: Niikawa (Application # 2002/0135688), Enomoto (Patent 6,323,934), and Yamasaki (Application # 2003/0071905).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground also builds on the Niikawa/Enomoto combination, adding Yamasaki to address limitations requiring analysis of a data file to separate objects based on "differentiation of the depth-of-field" and applying filtration only to those specific objects. Petitioner contended that Yamasaki explicitly discloses a "digital portrait mode" that changes the depth of field to control the blur effect of objects other than the principal subject, thereby separating objects in the image.
    • Motivation to Combine: A POSITA would combine Yamasaki's teachings with the Niikawa/Enomoto system to create more sophisticated and aesthetically pleasing images, such as portraits with a sharp subject and blurred background. Niikawa discloses a similar but simpler method of synthesizing two images focused at different depths. A POSITA would be motivated to use Yamasaki’s more advanced depth-of-field analysis to improve this functionality.
    • Expectation of Success: A POSITA would expect success in implementing Yamasaki’s depth-of-field differentiation technique within the Niikawa/Enomoto framework, as it involved applying a known image analysis method (object separation based on focus) to achieve a desirable and predictable photographic effect.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Niikawa alone and Niikawa in view of only Levien, relying on similar arguments regarding the interchangeability of known camera components and image processing techniques.

4. Arguments Regarding Discretionary Denial

  • This petition is a follow-on "copycat" petition to a previously filed IPR (IPR2024-01373). Petitioner argued that discretionary denial under General Plastic is unwarranted because it intends to file a motion for joinder, which neutralizes concerns of serial petitions or harassment. Petitioner also argued against denial under Fintiv, noting it has stipulated not to pursue in district court any grounds raised or that reasonably could have been raised in this IPR, thereby mitigating concerns of duplicative efforts and conflicting decisions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9 and 18-24 of the ’805 patent as unpatentable.