Snap Inc v. Nokia Technologies Oy

1. Case Identification

• Case #: IPR2025-01114
• Patent #: 8,175,148
• Filed: June 16, 2025
• Petitioner(s): Snap Inc.
• Patent Owner(s): Nokia Technologies Oy
• Challenged Claims: 1-23

2. Patent Overview

• Title: Video Coding
• Brief Description: The ’148 patent discloses a method for video encoding that introduces a sequence-level quantization parameter (SQP) into the bitstream to serve as a "default or reference level of quantization." An encoder can adjust the actual quantization parameter (QP) for specific slices or macroblocks and transmit only the difference (ΔQP), allowing a decoder to efficiently reconstruct the correct QP for decompression.

3. Grounds for Unpatentability

Ground 1: Claims 1-23 are obvious over MPEG-1

• Prior Art Relied Upon: MPEG-1 (ISO/IEC 11172-2, publicly available by Oct. 1993).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the MPEG-1 video compression standard discloses all limitations of the challenged claims. Specifically, MPEG-1’s syntax includes a non_intra_quantizer_matrix in the sequence header, which Petitioner asserted serves as the claimed "default level of quantization." This matrix is applied throughout a video sequence unless updated by a subsequent sequence header. MPEG-1 provides this matrix to the decoder via a one-bit flag (load_non_intra_quantizer_matrix) and, if the flag is set, the matrix values themselves, thereby teaching an "indication of the default level" provided to a decoding process. Furthermore, MPEG-1 discloses a quantizer_scale parameter at the slice or macroblock level, which scales the default matrix. Petitioner contended that using a quantizer_scale value other than "1" results in a "level of quantization different from the default," and the quantizer_scale value itself provides an "indication of a difference" between the default and actual quantization levels, as required by various dependent claims.
  • Motivation to Combine: Not applicable (single reference ground).
  • Expectation of Success: Not applicable (single reference ground).

Ground 2: Claims 1-22 are obvious over H.263

• Prior Art Relied Upon: H.263 (ITU-T Recommendation H.263, publicly available by May 2000).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that the H.263 video compression standard renders the claims obvious. H.263 defines a quantization parameter, PQUANT, in the header of each picture (frame). Petitioner argued that PQUANT constitutes a "default level of quantization" for that picture. This default can be updated for specific Groups of Blocks (GOBs) or macroblocks within the picture using optional GQUANT or DQUANT parameters, respectively. The use of GQUANT or DQUANT results in quantization "based on a level of quantization different from the default level" set by PQUANT. Petitioner specifically pointed to DQUANT, a two-bit code that defines a differential change to the current quantization value, as teaching an "indication of a difference" provided to the decoding process. Because PQUANT is provided for each picture, Petitioner argued the default level is "updated during the encoding of the digital video sequence" from one frame to the next.
  • Motivation to Combine: Not applicable (single reference ground).
  • Expectation of Success: Not applicable (single reference ground).

4. Key Claim Construction Positions

• Petitioner proposed constructions for several means-plus-function (MPF) limitations in claims 12 and 23, which are central to its invalidity arguments.
• "Means for Encoding" (claim 12) / "Module for Encoding" (claim 23):
  • Function: Applying motion compensated prediction to blocks of pixels and providing corresponding blocks of prediction error values.
  • Proposed Structure: A motion-compensated predictor and a combiner.
• "Means for Transforming" (claim 12) / "Module for Transforming" (claim 23):
  • Function: Providing sets of transform coefficient values representative of blocks of prediction error values.
  • Proposed Structure: A transform block (e.g., a DCT transformer).
• "Means for Selecting" (claim 12) / "Module for Selecting" (claim 23):
  • Function: Selecting a default level of quantization for quantizing sets of transform coefficient values.
  • Proposed Structure: A control manager that controls the quantization process to manage bitrate.
• "Means for Providing" (claim 12):
  • Function: Providing an indication of the default level of quantization in the encoded bit-stream.
  • Proposed Structure: A video multiplex coder that assembles control information into a bitstream.

5. Arguments Regarding Discretionary Denial

• Petitioner acknowledged that a previous IPR challenging the ’148 patent (IPR2024-01176) was instituted but later terminated due to settlement. Petitioner asserted that it had no involvement and was not a real party in interest in the prior IPR, arguing that discretionary denial would be inappropriate.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-23 of the ’148 patent as unpatentable.