Google LLC v. Advanced Coding Technologies LLC

1. Case Identification

• Case #: IPR2025-00999
• Patent #: 9,986,303
• Filed: May 12, 2025
• Petitioner(s): Google LLC
• Patent Owner(s): Advanced Coding Technologies LLC
• Challenged Claims: 1-2

2. Patent Overview

• Title: Video Image Coding Data Transmitter, Method, Receiver, and System
• Brief Description: The ’303 patent describes a video transmission technology that uses a hierarchical coding structure to adapt to varying network bandwidth. The system codes video pictures as either "basic hierarchical pictures" in a basic hierarchy or "supplemental hierarchical pictures" in a supplemental hierarchy, allowing for delayed transmission of supplemental data to be combined later with basic data for higher-quality playback when bandwidth improves.

3. Grounds for Unpatentability

Ground 1: Obviousness over Demircin - Claims 1-2 are obvious over Demircin.

• Prior Art Relied Upon: Demircin (Application # 2008/0181302).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Demircin teaches a Scalable Video Coding (SVC) system that is analogous to the ’303 patent's claimed invention. Demircin’s mandatory "base layer," which provides a minimum level of video quality, corresponds to the claimed "basic video image coding data." Its optional "enhancement layers," which provide incremental quality improvements, correspond to the claimed "supplementary video image coding data." Demircin’s system prioritizes transmission of base layer data when bandwidth is low and can discard enhancement layer data. Critically, Demircin also taught that discarded enhancement layer data can be transmitted belatedly during an "idle interval" when bandwidth becomes available. Petitioner contended this directly teaches acquiring previously received basic data from a buffer to reconstruct a higher-quality image with newly received supplementary data.
  • Motivation to Combine (N/A): This ground is based on a single reference.
  • Expectation of Success (N/A): This ground is based on a single reference.
  • Key Aspects: Petitioner asserted that Demircin’s explicit disclosure of delayed NAL (Network Abstraction Layer) unit transmission for enhancement layers, combined with typical video buffering, renders obvious the key limitation of claim 1: a supplementary picture having a coding and display order earlier than a basic picture that is transmitted later in time.

Ground 2: Obviousness over Chen - Claims 1-2 are obvious over Chen.

• Prior Art Relied Upon: Chen (Application # 2012/0016965).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Chen teaches techniques for a client device to seamlessly switch between different video "representations" (e.g., a high-bandwidth and a low-bandwidth stream) without interrupting playback. Petitioner mapped Chen’s higher-quality first representation to the claimed "basic video image coding data" and the lower-quality second representation to the "supplementary video image coding data." Chen taught that a client device buffers data from the first representation to ensure a smooth transition. Petitioner contended that Chen’s disclosure of buffering a fragment of the first representation that "overlaps" a random access point in the second representation meets the claim limitation requiring a supplementary picture with a coding/display order earlier than a basic picture.
  • Motivation to Combine (N/A): This ground is based on a single reference.
  • Expectation of Success (N/A): This ground is based on a single reference.
  • Key Aspects: The core of this argument relied on Chen's teaching that video samples are illustrated in "decoding time order." Therefore, a random access point in the second stream (supplementary picture) shown earlier in time than a sample in the first stream (basic picture) inherently has an earlier decoding and display order, rendering the claim obvious.

Ground 3: Obviousness over Chen in view of Karczewicz - Claim 2 is obvious over Chen in view of Karczewicz.

• Prior Art Relied Upon: Chen (Application # 2012/0016965) and Karczewicz (Patent 6,765,963).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground specifically addressed limitation [2.4] of claim 2, which requires the transmitter to perform "acquiring the transmission rate of a network." While Petitioner argued Chen alone rendered this obvious (by having the transmitter react to requests from the receiver that imply a change in bandwidth), it presented this combination as an alternative. Karczewicz explicitly taught a server that "dynamically switches between the streams to accommodate variations of the bandwidth available to the client," thereby directly teaching a transmitter acquiring the network transmission rate.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Karczewicz's server-side bandwidth determination with Chen's system as a simple substitution of one known technique for another (client-side determination). This combination represented a finite number of predictable solutions for managing adaptive bitrate streaming.
  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in implementing Karczewicz's server-side rate acquisition into Chen's framework to achieve the same goal of adaptive streaming.

4. Key Claim Construction Positions

• "reconstructing... from the basic... and the supplementary... data": Petitioner noted that in a prior IPR, the Patent Owner proposed construing this term as "rearranging basic video coding data with supplementary video image coding data." Petitioner argued its grounds render the claims obvious even under this narrower construction, as both Demircin and Chen teach combining earlier-received base/basic layer data with later-received enhancement/supplementary data to produce a final video stream.
• "basic" vs. "supplementary" data: Petitioner also addressed the Patent Owner’s prior proposed interpretation that "supplementary" data provides separate pictures from, and does not add quality to, "basic" data. Petitioner argued that the prior art teaches systems that meet the claims under any reasonable interpretation, including the Patent Owner's narrow view.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §325(d), asserting that the petition presented new prior art (Demircin, Chen, Karczewicz) and arguments that were not considered during the original examination. The art cited by the Examiner was materially different from the art relied upon in the petition.
• Petitioner also contended that discretionary denial under Fintiv was inappropriate. The co-pending district court litigation was in a very early stage, with claim construction and trial scheduled for late 2025 and 2026, respectively. Furthermore, under the General Plastic factors, Petitioner noted it had not previously challenged the ’303 patent and was not the "same party" as a prior petitioner (Samsung), weighing strongly in favor of institution.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2 of the ’303 patent as unpatentable.