PTAB

IPR2025-00991

Apple Inc v. Advanced Coding Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: MOVING-PICTURE CODING APPARATUS, METHOD AND PROGRAM, AND MOVING-PICTURE DECODING APPARATUS, METHOD AND PROGRAM
  • Brief Description: The ’025 patent discloses a moving-picture coding and decoding system that generates a predictive picture while maintaining video signal continuity. The system adaptively switches between a conventional motion compensation mode and a "zone-border" motion compensation mode, which uses border information and Poisson's Equation to estimate video signals in rectangular zones.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Error Concealment References - Claims 1-10 are obvious over Mualla, Shirani, and Saito (Ground 1A) and further in view of Stockhammer (Ground 1B).

  • Prior Art Relied Upon: Mualla (a 2002 Elsevier treatise), Shirani (a June 2000 IEEE Journal article), Saito (a Jan. 2006 journal article), and Stockhammer (a July 2003 IEEE Trans. article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the claimed invention was a predictable combination of known video coding and error concealment techniques. Mualla, a foundational treatise, was said to teach a standard H.263 video codec and describe hybrid (temporal and spatial) error concealment for handling data loss. Shirani, explicitly cited by Mualla, allegedly disclosed a specific two-stage error concealment method: a first temporal stage using motion vectors from adjacent blocks to estimate the borders of a missing block, and a second spatial stage to refine the estimate using information around the block. Petitioner contended that a POSITA would have implemented the second spatial stage using the technique taught by Saito, which used Poisson's equation for image approximation to improve visual quality and reduce blocking artifacts. Stockhammer was asserted to provide well-known implementation details for a feedback-based error concealment system, which Petitioner argued would have been within the general knowledge of a POSITA or found through a routine search.
    • Motivation to Combine: Petitioner asserted a strong motivation to combine these references. A POSITA would combine Mualla and Shirani because Mualla explicitly directed the reader to Shirani for details on implementing hybrid error concealment. The motivation to then incorporate Saito was to improve the known spatial concealment stage of Shirani by applying Saito's advanced Poisson-based image processing, a technique known to enhance perceptual quality, which is a key goal in video coding.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because the combination involved applying known, compatible techniques to a standard video codec to achieve the predictable result of improved error resilience and visual quality.

Ground 2: Obviousness with Adaptive Prediction Selection - Claims 1-10 are obvious over Mualla, Shirani, and Saito in view of Shimizu.

  • Prior Art Relied Upon: Mualla (a 2002 Elsevier treatise), Shirani (a June 2000 IEEE Journal article), Saito (a Jan. 2006 journal article), and Shimizu (Application # 2003/0174776).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Mualla-Shirani-Saito combination from Ground 1, arguing that its two-stage predictive method could be used not only for error concealment but also for general prediction in error-free environments to improve coding efficiency. Petitioner introduced Shimizu, which taught an encoder that adaptively selected between two different motion compensation modes (conventional "local" and "global") on a block-by-block basis to reduce the generated code size. Petitioner argued it would be obvious to apply Shimizu's adaptive switching framework to the system from Ground 1. This would result in a system that could select between conventional motion compensation and the more complex Mualla-Shirani-Saito prediction method, choosing whichever was more efficient for a given block based on the resulting data amount.
    • Motivation to Combine: The primary motivation was to improve overall coding efficiency, a central goal in video compression. Petitioner argued that since the error resilience technique from Ground 1 could also function as a general predictive coding tool, a POSITA would be motivated by Shimizu's teachings to create a system that could dynamically choose the most efficient prediction method for any given situation, thereby reducing the final bit rate.
    • Expectation of Success: A POSITA would expect success in combining these teachings, as it amounted to using a known technique for adaptive mode selection (from Shimizu) to arbitrate between two known predictive coding methods (conventional and the Mualla-Shirani-Saito combination) to optimize a predictable performance metric like coding efficiency.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. The petition noted the existence of a prior IPR on the ’025 patent (IPR2024-00374) that was instituted but terminated before a final written decision. Petitioner also stated its intent to use the bifurcated briefing process under the USPTO's Stewart Memorandum to rebut any discretionary denial arguments raised by the Patent Owner.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-10 of the ’025 patent as unpatentable.