PTAB

IPR2025-00983

Apple Inc v. Advanced Coding Technologies LLC

Key Events

Petition

petition

Title: VIDEO IMAGE CODING DATA TRANSMITTER, VIDEO IMAGE CODING DATA TRANSMISSION METHOD, VIDEO IMAGE CODING DATA RECEIVER, AND VIDEO IMAGE CODING DATA TRANSMISSION AND RECEPTION SYSTEM
Brief Description: The ’303 patent describes technology for transmitting hierarchically coded video data. The system divides video data into a "basic" hierarchy for a baseline quality level and a "supplementary" hierarchy that enhances the video, allowing for flexible transmission over channels with changing bandwidth.

Prior Art Relied Upon: Demircin (Application # 2008/0181302).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Demircin discloses a Scalable Video Coding (SVC) system that addresses variable network bandwidth, which is the same problem addressed by the ’303 patent. Demircin teaches a "base layer" (basic video data) and "enhancement layers" (supplementary video data) organized into Groups of Pictures (GOPs). To manage bandwidth, Demircin’s system prioritizes transmitting the base layer while enhancement layer frames can be temporarily discarded and transmitted later during an "idle interval." Petitioner asserted that a receiver in Demircin’s system would acquire the earlier-received base layer data from a buffer and reconstruct it with the later-received enhancement layer data to produce a higher quality video stream, thus meeting the limitations of claims 1 and 2. The temporal structure of Demircin's GOPs, with I-frames in the base layer and B-frames in enhancement layers, was alleged to meet the claim requirements for basic and supplementary hierarchical pictures.

Prior Art Relied Upon: Demircin (Application # 2008/0181302) and Kimoto (Application # 2011/0211631).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted this combination strengthens the argument for the "acquiring" and "reconstructing" limitations. Kimoto explicitly teaches a system where a receiver receives and stores "lower layer" data (basic data) for a video long before receiving any "upper layer" data (supplementary data). Kimoto's receiver then acquires the stored lower layer data from memory and synthesizes it with the later-received upper layer data to form high-quality data. Applying Kimoto’s explicit teachings to Demircin's system would involve acquiring stored base layer frames to synthesize with delayed enhancement layer frames.
- Motivation to Combine (for §103 grounds): A POSITA would combine Kimoto’s teachings with Demircin’s system to better ensure that frames with delayed transmission are properly ordered for decoding. This combination would provide a reliable method to prevent decoding errors and achieve predictable benefits, such as allowing users to preview video at a lower quality before all data is received, a scenario described by Kimoto.
- Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because both references describe similar hierarchical coding techniques, and rearranging coded frames was a well-known technique in the art.

Prior Art Relied Upon: Kimoto (Application # 2011/0211631) and Demircin (Application # 2008/0181302).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kimoto teaches the core concept of the invention: receiving and storing lower layer data first, then later receiving upper layer data and synthesizing the two to create a high-quality video. However, Petitioner contended Kimoto does not explicitly disclose organizing this data into GOPs that include an intra-coded picture and a plurality of inter-prediction coded pictures. Demircin was argued to supply this teaching with its detailed description of a GOP structure (e.g., one I-frame and multiple B-frames) used for scalable video coding.
- Motivation to Combine (for §103 grounds): A POSITA would be motivated to modify Kimoto’s system with Demircin’s GOP structure to improve the accuracy and efficiency of synthesizing the lower and upper layer data. This structure would also facilitate random playback capabilities and provide a robust method for adapting to variable bandwidth, particularly for mobile terminals, a use case explicitly mentioned in Kimoto.
- Expectation of Success (for §103 grounds): A POSITA would have expected success because using GOPs was a standard and well-known practice for implementing temporal scalability in hierarchical video coding systems like the one described by Kimoto.

Petitioner noted that in a prior litigation (to which Petitioner was not a party), the following terms were stipulated:
- "a factor of a group of pictures" was construed as "one or more groups of pictures."
- "reconstructing video image coding data..." was construed as "rearranging basic video image coding data with supplementary video image coding data."
Petitioner took no position on these constructions but argued the challenged claims are obvious even if these constructions are applied.

Petitioner argued that discretionary denial is unwarranted. It stated its intent to utilize the bifurcated briefing process introduced by the March 26, 2025, Stewart Memorandum to rebut any contentions regarding discretionary denial that the Patent Owner might offer.

Petitioner requests institution of IPR and cancellation of claims 1-2 of the ’303 patent as unpatentable.