PTAB

IPR2025-01038

Intel Corp v. General Video LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Encoding Data for Transmission
  • Brief Description: The ’437 patent relates to transmitting encoded data, such as auxiliary audio data, over a serial link. The invention encodes the auxiliary data using a "robust subset" of a full set of code words to reduce inter-symbol interference (ISI) and transmits these bursts of auxiliary data during the blanking intervals between bursts of conventionally encoded video data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kim, Shin, and Myers - Claims 41-45, 47, 49-50, and 52-53 are obvious over the combination of Kim, Shin, and Myers.

  • Prior Art Relied Upon: Kim (Patent 5,835,498), Shin (Patent 5,974,464), and Myers (Patent 5,625,644).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the prior art teaches all limitations of the challenged claims. Kim disclosed a system for sending multiple data streams over a serial line, specifically teaching the transmission of auxiliary data, like audio, within the unused bandwidth of horizontal and vertical blanking periods of a primary video stream. This, Petitioner asserted, teaches the core concept that led to the ’437 patent’s allowance during prosecution. Myers taught a technique for improving data transmission reliability by selecting a "robust subset" of code words from a full set. This subset is selected based on criteria that reduce data loss, such as ensuring DC balance (an equal number of ones and zeros) and limiting the run-length of consecutive identical bits. Petitioner contended this directly maps to the ’437 patent's "robust subset" for encoding auxiliary data. Shin, which is expressly incorporated by reference in Kim, provided a detailed, conventional 8b/10b encoding scheme that serves as the "full code word set" from which Myers' subset selection technique could be applied.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to achieve a predictable improvement in data transmission. Petitioner argued a POSITA would be motivated to apply the subset-selection technique of Myers to the audio data encoders in Kim's system. This motivation stems from the common knowledge that the human ear is more sensitive to errors than the human eye, making it desirable to encode audio data more robustly than video data to reduce data loss. Myers provided a known, well-documented method to increase robustness and reduce data loss. Therefore, applying Myers' technique to improve the known system of Kim was a matter of applying a known solution to a known problem to yield predictable results. The motivation to use Shin's encoding scheme was explicit, as Kim incorporated Shin by reference as an exemplary encoding method for its system.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success. Both Kim and Myers relate to serial data transmission, making the techniques compatible. Myers provided clear, step-by-step instructions for selecting the code word subset, making the outcome of the combination predictable. Applying Myers' known technique for improving reliability to Kim's known method for transmitting audio data was a straightforward design choice with a high likelihood of success.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) would be inappropriate. The petition noted co-pending district court litigation involving the ’437 patent and, to address potential Fintiv concerns, offered a stipulation consistent with Sotera Wireless. If the PTAB institutes this inter partes review (IPR), Petitioner Dell stipulated it will not pursue in the litigation the specific grounds raised in the petition or any other grounds that could have reasonably been raised in the IPR based on prior art patents or printed publications.

5. Relief Requested

  • Petitioner requested that the Board institute an IPR trial and cancel claims 41-45, 47, 49-50, and 52-53 of the ’437 patent as unpatentable under 35 U.S.C. §103.