PTAB

IPR2025-00462

Samsung Electronics Co Ltd v. Optimum Imaging Technologies LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Digital Imaging System for Correcting Optical Image Aberrations
  • Brief Description: The ’339 patent discloses a digital imaging system designed to perform in-camera correction of optical aberrations. The system uses a microprocessor, system software, and a database management system to identify specific lens aberrations and apply corresponding correction algorithms via a digital signal processor before storing the optimized image file in memory.

3. Grounds for Unpatentability

Ground 1: Obviousness over Niikawa and Enomoto - Claims 1-3, 5, 14-15, and 17-18 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 asserted that Niikawa discloses a digital camera system with all the core components recited in independent claims 1 and 14, including a microprocessor (general controller), a digital signal processor (shading corrector), system software (programs in ROM), and a database (correction tables in shading ROM). Niikawa’s system corrects a specific optical aberration known as shading (vignetting). Enomoto was introduced to teach the correction of multiple, different types of aberrations (e.g., chromatic aberration, distortion) by storing various lens characteristics in a database and applying corresponding correction functions.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Enomoto’s teaching of correcting multiple aberration types with Niikawa’s foundational camera system to improve overall image quality. Since Niikawa’s stated purpose was to improve image quality, a POSITA would have been motivated to extend its single-aberration correction capability to address other known aberrations as taught by Enomoto, which was a known technique for improving similar devices.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Enomoto discloses that its processor identifies multiple aberrations for correction, similar to how Niikawa’s controller identifies shading aberrations. Implementing this modification would be straightforward.

Ground 2: Obviousness over Matsutani and Shiomi - Claims 1-2, 14-15, and 17 are obvious over Matsutani in view of Shiomi.

  • Prior Art Relied Upon: Matsutani (Japanese Application # 2004-266768) and Shiomi (Japanese Application # H5-3568).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Matsutani teaches a digital camera that corrects various aberrations using a real-time processing unit (RPU), which functions as a digital signal processor performing convolution operations. Matsutani discloses the core components of a camera system that reads correction data from memory to correct aberrations caused by the optical mechanism. While Matsutani teaches correcting for various focal lengths, Shiomi was cited for its explicit disclosure of a zoom lens system that uses tables of "aberration correction coefficients" indexed to specific focal length and focusing lens movement information to correct chromatic aberration.
    • Motivation to Combine: The motivation was strong, as Petitioner asserted Matsutani itself suggests using correction techniques like those taught in Shiomi. A POSITA would have been motivated to incorporate Shiomi's detailed zoom lens correction method into Matsutani's more general aberration correction framework to create a robust system for cameras with zoom lenses.
    • Expectation of Success: Success would be expected because both references solve the same problem of in-camera aberration correction using stored coefficients. Combining Shiomi's specific tables for zoom lens focal lengths with Matsutani's processing architecture represents a predictable integration of known technologies.

Ground 3: Obviousness over Matsutani, Shiomi, and Ito - Claims 4 and 16 are obvious over Matsutani in view of Shiomi and Ito.

  • Prior Art Relied Upon: Matsutani (Japanese Application # 2004-266768), Shiomi (Japanese Application # H5-3568), and Ito (Japanese Application # H6-113309).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds upon the combination of Matsutani and Shiomi to specifically address claims 4 and 16, which require the use of a fast Fourier transform (FFT) algorithm. Petitioner argued that Ito explicitly teaches using an FFT algorithm as part of digital signal processing to correct chromatic aberrations in a digital video camera.
    • Motivation to Combine: A POSITA, seeking to implement the aberration correction system of Matsutani and Shiomi, would be motivated to use the FFT algorithm from Ito because FFT was a well-known and powerful tool for digital filtration and solving aberrations. The ’339 patent’s applicant even conceded during prosecution that there was "no reason not to include a powerful class of algorithm [like FFT] to the toolbox."
    • Expectation of Success: A POSITA would have a high expectation of success in applying Ito's FFT algorithm within Matsutani’s RPU, as it would be a known technique for improving the digital signal processing capabilities of the system to achieve more accurate correction of chromatic and other aberrations.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims obvious over Niikawa alone (Ground 1a), claims obvious over Niikawa in view of Ito with and without Enomoto (Grounds 2a and 2b), and claims obvious over Matsutani in view of Shiomi and Enomoto II (Ground 4). These grounds relied on similar arguments and combinations of the primary references.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be unwarranted. The petition asserted that denial under General Plastic is inapplicable because this filing is a "copycat" of a previously filed petition (IPR2024-01372) and Petitioner intended to file for joinder, which neutralizes concerns of serial challenges.
  • Petitioner further argued that discretionary denial under Fintiv is inappropriate because it provided a Sotera stipulation, agreeing not to pursue in district court the same grounds raised or any grounds that reasonably could have been raised in the IPR if instituted.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 14-18 of Patent 8,451,339 as unpatentable.