PTAB

IPR2025-00984

Apple Inc v. Advanced Coding Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Moving Picture Encoding System, Moving Picture Encoding Method, etc.
  • Brief Description: The ’995 patent describes layered video coding systems that apply super-resolution processing to enhance reference pictures. This technique is used to improve both an original input video stream and the reference pictures used for predicting subsequent pictures in the enhanced stream.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Phek, Segall, Martins, and He - Claims 2-4 and 11 are obvious over Phek in view of Segall, Martins, and He.

  • Prior Art Relied Upon: Phek (Japanese Publication No. 2007316161), Segall (a 2007 IEEE paper on Scalable Video Coding), Martins (a 2002 IEEE paper on resolution enhancement), and He (Application # 2008/0137753).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Phek discloses a foundational hierarchical video coding system using super-resolution processing to improve reference pictures for an enhancement layer. The asserted combination modifies Phek’s system with other known techniques.
      • Segall allegedly taught implementing layered coding where base and enhancement layers have the same spatial resolution (e.g., for quality or temporal scalability) and adding further enhancement layers for spatial scalability. This addresses limitations regarding multiple layers and resolutions.
      • Martins allegedly taught a "decimation" process to downscale super-resolution enlarged images back to a standard resolution while retaining enhanced quality. This addresses the "first resolution converter" limitation.
      • He allegedly taught selectively enabling or disabling in-loop filters (like deblocking filters) based on control information in the bitstream to balance quality and computational complexity. Petitioner argued it would be obvious to apply this selective filtering concept to Phek’s super-resolution process, which functions as a loop filter. This modification allegedly meets the limitation of selecting between a first set of reference pictures (non-enhanced) and a second set (super-resolution enhanced) based on "reference picture selection information."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve Phek’s known system. Segall provided well-known scalability options. Martins offered a way to manage resolution and reduce computational/memory load after super-resolution processing. He provided a standard method for managing the trade-off between the quality improvement from a loop filter and its associated processing cost.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying known techniques (scalable coding, downscaling, selective filtering) to a conventional video coding architecture (Phek) to achieve predictable benefits in performance and efficiency.

Ground 1B: Obviousness over Phek, Segall, Martins, and Takahashi - Claims 2-4 and 11 are obvious over Phek in view of Segall, Martins, and Takahashi.

  • Prior Art Relied Upon: Phek (Japanese Publication No. 2007316161), Segall (a 2007 IEEE paper), Martins (a 2002 IEEE paper), and Takahashi (Application # 2001/0043751).
  • Core Argument for this Ground: This ground is substantially similar to Ground 1A, but substitutes Takahashi for He to teach the selective use of different reference pictures.
    • Prior Art Mapping: The teachings of Phek, Segall, and Martins are applied as in Ground 1A. Takahashi is introduced to provide an alternative and allegedly more explicit teaching for the "select one of the set of first... and second reference pictures" limitation. Takahashi allegedly disclosed a hierarchical coding system with a selection switch that chooses between different reference pictures (e.g., high-resolution vs. resolution-converted) based on the coding mode of the frame to improve efficiency.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to incorporate Takahashi’s selection switch into the Phek-Segall-Martins combination to optimize compression and computational efficiency. Takahashi explicitly taught selecting between reference pictures with different information densities to reduce operational processing and simplify circuit configuration, providing a clear motivation for its inclusion.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as implementing selection switches for reference pictures was a well-known technique for managing efficiency in hierarchical video coding systems before the critical date.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It stated its intent to use the bifurcated briefing process contemplated by the March 26, 2025, Stewart Memorandum to rebut any contentions for discretionary denial raised by the Patent Owner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 2-4 and 11 of the ’995 patent as unpatentable.