PTAB

IPR2025-01158

Apple Inc v. Advanced Coding Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Moving Picture Encoding System, Moving Picture Encoding Method...
  • Brief Description: The ’995 patent describes a hierarchical video coding system that uses "super-resolution" processing to enhance reference pictures. The system encodes a standard-resolution base layer and a higher-quality enhancement layer, employing multiple encoders, enlargers, and resolution converters to improve encoding efficiency.

3. Grounds for Unpatentability

Ground 1: Claims 1, 6, and 8-10 are obvious over Phek, YuChuan, and He.

  • Prior Art Relied Upon: Phek (Japanese Application # 2007316161), YuChuan (US Application # 2004/0156561), and He (US Application # 2008/0137753).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Phek disclosed the foundational hierarchical video coding system with a base layer encoder and an enhancement layer encoder. Phek taught using super-resolution processing on decoded base layer pictures to create reference pictures for the enhancement layer. To meet the claim limitations for a "first super-resolution enlarger" and a "first resolution converter," Petitioner asserted it would have been obvious to apply super-resolution to the base layer input stream to generate the enhancement layer input stream, and then use a down-sampling process as taught by YuChuan to return the stream to the standard resolution. This would create an enhanced-quality stream at the same spatial resolution as the base layer.
    • To meet the limitations requiring a selection between two sets of reference pictures, Petitioner argued that the combination of super-resolution and subsequent downscaling (termed "SR-D") functions as a type of in-loop filter. He taught selectively enabling or disabling an in-loop deblocking filter to balance video quality against computational cost. A POSITA would have recognized that the computationally expensive SR-D process could be similarly made selective, thereby creating two sets of reference pictures: one that is SR-D processed and one that is not.
    • Motivation to Combine: A POSITA would combine Phek and YuChuan to implement "quality scalability" (enhancing quality while maintaining the same spatial resolution), a well-known and desirable objective in video coding. A POSITA would further incorporate He's teachings to manage the significant computational cost of super-resolution, a known problem, by making its application selective. This represents the application of a known technique (selective filtering) to solve a known problem (high computational load) within a known system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying known techniques to a conventional layered coding system to achieve the predictable results of improved quality scalability and efficient resource management.

Ground 2: Claims 1, 5-6, and 8-10 are obvious over Phek, YuChuan, He, and Martins.

  • Prior Art Relied Upon: Phek (Japanese Application # 2007316161), YuChuan (US Application # 2004/0156561), He (US Application # 2008/0137753), and Martins (an IEEE paper from September 2002).
  • Core Argument for this Ground:
    • Prior Art Mapping: For claims 1, 6, and 8-10, the Petitioner’s argument was substantially the same as in Ground 1, with Martins presented as an alternative or corroborating reference to YuChuan. Martins taught a super-resolution algorithm based on motion-compensated spatial upsampling followed by "decimation to the desired format," which could include the original standard resolution, thus reinforcing the obviousness of the claimed resolution converters.
    • For claim 5, which recites specific components of a super-resolution enlarger, Petitioner argued Martins rendered these limitations obvious. Martins disclosed aligning pixels from reference pictures using motion estimation ("positioner"), using spatial interpolation to complete the upsampled image ("interpolator"), creating a final super-resolution picture ("estimated picture creator"), and determining if further processing is needed to reach a "Final Resolution" ("repetition determiner").
    • Motivation to Combine: The motivation was identical to Ground 1. Martins represented another known and available design choice for implementing a super-resolution and downscaling process. Applying Martins' method would predictably improve the quality of the SR-D filtering process without materially degrading the signal-to-noise ratio upon downscaling.
    • Expectation of Success: A POSITA would have expected success for the same reasons as Ground 1. The selection of Martins' specific super-resolution technique from among the various known methods would have been an obvious design choice to achieve predictable quality enhancements.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 5-6, and 8-10 of the ’995 patent as unpatentable.