PTAB

IPR2025-01014

Snap Inc v. Nokia Technologies Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Grouping of Image Frames in Video Coding
  • Brief Description: The ’321 patent relates to methods and apparatuses for encoding and decoding video by grouping image frames into "independent sequences." It purports to solve issues with resuming playback mid-stream by defining an initiation image and resetting its identifier value to zero for the first frame of each such independent sequence.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kim - Claims 1, 3-4, 6-8, and 10-11 are obvious over Kim.

  • Prior Art Relied Upon: Kim (Patent 6,912,351).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim, which discloses a device and method for recording and reproducing time-lapse video data, teaches all limitations of the challenged claims. Kim describes encoding a video bitstream with a "logical structure" comprising I-pictures and P-pictures. Petitioner asserted that a group of frames starting with an I-picture and followed by P-pictures that depend only on that I-picture constitutes the claimed "independent sequence." The limitation of "encoding... an indication" of the first frame is met by Kim's disclosure of an I-picture reference address (IAD) that is set to zero for each I-picture, thereby indicating it is the first frame of a new sequence. Kim’s use of "logical addresses," composed of the IAD and an incrementing Current Address (CAD), was argued to be the claimed "identifier values" encoded according to a "numbering scheme." The "resetting the identifier value" limitation is met because the IAD component of the logical address is reset to zero for each new I-picture, which begins each independent sequence. The arguments for the decoder-side claims (8, 10, 11) mirrored the encoder-side claims, asserting Kim's disclosure of a reproducing/decoding method teaches the corresponding decoding steps.
    • Key Aspects: This ground asserted that Kim’s fundamental architecture for structuring and addressing time-lapse video frames inherently contains every element of the claims without modification.

Ground 2: Obviousness over Kim and Adolph - Claims 2, 5, and 9 are obvious over Kim in view of Adolph.

  • Prior Art Relied Upon: Kim (Patent 6,912,351) and Adolph (Patent 5,838,265).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that claims 2, 5, and 9 add the limitation of encoding the start-of-sequence "indication as a separate flag included in the header of a slice." Kim was asserted to teach the underlying video structure and the indication itself (the IAD value of zero). Adolph was presented as teaching an MPEG-compliant video coding technique for improving error resilience by inserting important picture-level information (such as frame type) into slice headers. Petitioner contended that Kim's IAD value of zero is important picture-level information that identifies the frame type (an I-picture) and its position as the start of a sequence. Therefore, applying Adolph's teaching to Kim's system would result in placing this indication in the slice header as a flag.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Adolph's known error resilience technique with Kim's MPEG-based system to solve a known problem. In Kim’s system, where all P-pictures in a sequence depend on a single I-picture, the loss of that I-picture's address information would render the rest of the sequence undecodable. Adolph explicitly teaches inserting such critical data into slice headers to make a video stream more robust against data loss. A POSITA would have been motivated to apply this well-understood solution to improve the reliability of Kim's system.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because both Kim and Adolph describe MPEG-compliant systems. The combination involved applying a known technique (Adolph) to a known video system (Kim) to achieve the predictable result of improved error resilience without requiring any undue experimentation.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-11 of the ’321 patent as unpatentable.