Google LLC v. Advanced Coding Technologies LLC

1. Case Identification

• Case #: IPR2025-00998
• Patent #: 8,090,025
• Filed: May 12, 2025
• Petitioner(s): Google LLC
• Challenged Claims: 1-10

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 video coding and decoding systems that can produce a predictive picture while maintaining video signal continuity. The invention describes selecting between an "ordinary" block-based motion compensation mode and a "zone-border" mode that uses gradient data and Poisson's Equation to handle prediction at block borders.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mualla, Shirani, Saito, and Takenaka - Claims 2, 5, 6, and 8 are obvious over Mualla in view of Shirani, Saito, and Takenaka.

• Prior Art Relied Upon: Mualla (a 2002 treatise on video coding), Shirani (a 2000 journal article on error concealment), Saito (a 2006 journal article on image analysis using Poisson's Equation), and Takenaka (Patent 4,743,967).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of references taught a video decoder that selects between two predictive modes. Mualla was asserted to teach a standard H.263 video codec, which forms the foundation of the claimed apparatus. The combination of Mualla and Shirani taught a two-stage "hybrid error concealment" technique, where Shirani provided a specific method using temporal concealment (first stage) followed by spatial concealment (second stage) to repair corrupted video blocks. Saito was argued to provide a known, advanced technique for performing the spatial concealment stage by solving Poisson's equation, which improves perceptual quality and reduces blocking artifacts. Finally, Takenaka was alleged to teach a selector circuit that adaptively and efficiently switches between different predictive modes—here, between the conventional motion compensation of Mualla and the hybrid error concealment mode of Mualla-Shirani-Saito.
  • Motivation to Combine: A POSITA would combine Mualla and Shirani because Mualla explicitly cited Shirani as a source for implementing the "hybrid error concealment" it described. A POSITA would have been motivated to incorporate Saito's techniques into the Mualla-Shirani combination to solve the well-known problem of visual artifacts in spatial concealment, as improving perceptual quality was a primary goal of error concealment systems. The motivation to add Takenaka was to improve processing speed and efficiency by implementing a known method for selecting between two parallel prediction schemes (conventional prediction vs. error concealment), a common design choice in video coding.
  • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success because all references operated within the known H.263 video coding framework. Combining these elements involved applying known techniques (e.g., spatial interpolation, mode selection) to solve predictable problems (e.g., transmission errors, visual artifacts) and would have yielded predictable results.

Ground 2: Obviousness over Mualla, Shirani, and Saito - Claims 1, 3, 4, 7, and 9-10 are obvious over Mualla in view of Shirani and Saito.

• Prior Art Relied Upon: Mualla (a 2002 treatise on video coding), Shirani (a 2000 journal article on error concealment), and Saito (a 2006 journal article on image analysis using Poisson's Equation).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground asserted that a subset of the challenged claims, which do not recite the selector or mode-switching elements, were rendered obvious by the combination of Mualla, Shirani, and Saito alone. Petitioner argued this combination taught all elements of a video coding and decoding apparatus that employs a sophisticated error concealment method. Mualla again provided the foundational H.263 codec. Shirani taught the two-stage (temporal and spatial) process for concealing errors in missing blocks by using information from adjacent blocks and the previous frame. Saito taught modifying the second (spatial) stage of Shirani's method by using an advanced image processing technique—solving Poisson's equation with Neumann boundary conditions derived from Shirani's "border errors"—to generate a visually superior estimated signal within the missing block.
  • Motivation to Combine: The motivation to combine Mualla and Shirani was based on Mualla's explicit citation of Shirani for details on hybrid error concealment. A POSITA would combine Saito's technique with the Mualla-Shirani system to improve the performance of the spatial concealment stage. Both the base combination and Saito shared the goal of improving the perceptual quality of reconstructed images for the human visual system, making Saito's advanced, state-of-the-art solution for image approximation a natural and obvious improvement.
  • Expectation of Success: A POSITA would have expected this combination to work successfully. The combination involved using a well-known image processing technique (solving Poisson's equation) to improve a specific, known step (spatial concealment) in a standard video coding system. The compatibility of the techniques was high, as Shirani's "border errors" provided a suitable input for the "boundary condition" required by Saito's method.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) or §314(a) would be inappropriate.
• New Art and Arguments: The petition asserted that none of the relied-upon prior art references (Mualla, Shirani, Saito, Takenaka) were considered or applied by the Examiner during the original prosecution of the ’025 patent.
• Fintiv Factors: Petitioner contended that the co-pending district court litigation is at a very early stage, with the trial not scheduled until March 2, 2026, well after the statutory deadline for a Final Written Decision in this IPR. This timeline minimizes any concern of duplicative efforts or inefficient use of resources.
• General Plastic Factors: Petitioner argued it is not the "same party" as, nor does it have a significant relationship with, Samsung, which previously filed IPR2024-00374 against the same patent. Therefore, this petition should not be viewed as an improper follow-on petition.

5. Relief Requested

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