PTAB

IPR2025-01153

ASUSTeK Computer Inc v. Nokia Technologies Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: METHOD FOR CODING AND AN APPARATUS
  • Brief Description: The ’714 patent discloses methods and an apparatus for improving video coding efficiency by reducing redundancy in motion vector prediction (MVP) candidate lists. The invention focuses on selectively comparing a potential candidate against a determined subset of existing candidates, rather than comparing every possible pair, to de-duplicate the list.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rusert and Karczewicz - Claims 1-3, 5-10, 12-17, 19-24, and 26-30 are obvious over Rusert in view of Karczewicz.

  • Prior Art Relied Upon: Rusert (Application # 2011/0194609) and Karczewicz (Application # 2011/0249721).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rusert, a reference based on the H.264 video coding standard, teaches the core inventive concept of the ’714 patent. Specifically, Rusert discloses a method of building a motion vector prediction candidate list by comparing a new candidate against a subset of previously coded motion vectors, thereby avoiding redundant comparisons and improving coding efficiency. Petitioner asserted that Karczewicz, which discusses the then-emerging H.265/HEVC standard, provides the necessary context for applying Rusert’s teachings to the H.265 environment, including its use of "Prediction Units" (PUs), which are analogous to the "blocks" described in Rusert.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine these references for several reasons. Rusert explicitly states that its principles, though described in the context of H.264, could be applied to other coding standards. Karczewicz teaches the concepts of the H.265 standard, the logical successor to H.264. A POSITA would have been motivated to apply Rusert's known efficiency-improving techniques for de-duplicating candidate lists to the newer H.265 framework taught by Karczewicz to achieve the predictable result of enhanced compression performance.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination represented a straightforward application of a known technique (Rusert's de-duplication) to a similar, next-generation system (Karczewicz's H.265). The underlying block-based motion prediction architecture is fundamentally similar in both H.264 and H.265, ensuring the combination would yield predictable improvements in coding efficiency.

Ground 2: Obviousness over Rusert, Karczewicz, and Lin - Claims 1-30 are obvious over Rusert and Karczewicz in view of Lin.

  • Prior Art Relied Upon: Rusert (Application # 2011/0194609), Karczewicz (Application # 2011/0249721), and Lin (Application # 2014/0092981).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Rusert/Karczewicz combination by adding the teachings of Lin to address claim limitations related to divided blocks (e.g., claim 4). Petitioner argued that Lin teaches a specific method for removing redundant candidates when a coding block is divided into two Prediction Units (e.g., a first and second PU). Lin discloses examining whether a block is divided and, if so, excluding a potential motion vector candidate from the list if the prediction unit being processed is the second prediction unit and the candidate is from the first. This prevents the motion vector from one half of a divided block, which likely has different motion, from being used as a predictor for the other half.
    • Motivation to Combine: Petitioner asserted that a POSITA would combine Lin with the primary references to further optimize the de-duplication process. The primary combination already aims to improve coding efficiency by reducing the candidate list. Lin provides a simple, logical rule for removing a specific type of redundant candidate that arises in a common scenario (divided blocks). Applying Lin's specific technique would be a straightforward enhancement to the general method taught by Rusert and Karczewicz, furthering the shared goal of improving compression.
    • Expectation of Success: The combination would have been expected to succeed because Lin's teaching is a discrete, targeted improvement that is fully compatible with the block-based prediction framework of the other references. Adding this specific rule for divided PUs would not alter the fundamental operation of the Rusert/Karczewicz system but would predictably enhance its efficiency, consistent with the rationale provided in Lin.

4. Key Claim Construction Positions

  • "the block" (limitation [1b]): Petitioner argued this term could refer to either (a) the "block of pixels" being coded, or (b) the block from which the "first spatial motion vector prediction candidate" is obtained. Petitioner contended its invalidity arguments held under either construction but noted that in a prior IPR, the PTAB construed the term to mean "the block associated with the first spatial motion vector prediction candidate."
  • "a subset of … candidates" (limitation [1b]): Petitioner asserted this phrase means a subset of one or more candidates. This construction is supported by dependent claim 3, which specifies comparing a candidate with "at most one other" candidate, implying the subset can be a single candidate.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’714 patent as unpatentable under 35 U.S.C. §103.