PTAB

IPR2025-01279

ASUSTeK Computer 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 discloses methods for decoding compressed video by grouping image frames into an "independent sequence." The invention aims to solve problems in video browsing, such as when a user starts viewing from a random point, by defining an initiation image for the sequence and resetting its identifier number to avoid decoding errors.

3. Grounds for Unpatentability

Ground 1: Obviousness over MPEG-1 - Claims 8, 10, and 11 are obvious over MPEG-1.

  • Prior Art Relied Upon: MPEG-1 (ISO/IEC 11172-2, 1st ed., published Aug. 1, 1993).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the well-known MPEG-1 video coding standard taught or suggested every limitation of claims 8, 10, and 11. MPEG-1’s concept of a "closed group of pictures" (closed GOP) is an "independent sequence" as claimed, as it can be decoded without reference to frames in any other group. The indication of the sequence's first frame is taught by either the closed_gop flag in the GOP header or the frame's "Temporal Reference" value being reset to zero. The method starts decoding from the first image frame of the independent sequence by identifying the group_start_code in the bitstream. MPEG-1’s "Temporal Reference" is an "identifier value" for each frame that is decoded according to a numbering scheme (incrementing by one for each frame in display order). This Temporal Reference is reset to zero for the first frame of each closed GOP, meeting the resetting limitation. Claims 10 and 11, which add a decoder apparatus and computer program product, respectively, were argued to be obvious implementations of the MPEG-1 decoding process using conventional hardware known to a POSITA.
    • Motivation to Combine (for §103 grounds): Not applicable (single-reference ground).
    • Expectation of Success (for §103 grounds): Not applicable (single-reference ground).

Ground 2: Obviousness over Kim - Claims 8, 10, and 11 are obvious over Kim.

  • Prior Art Relied Upon: Kim (Patent 6,912,351).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Kim, which discloses a method for reproducing video data, rendered the claims obvious. Kim’s grouping of an I-picture followed by dependent P-pictures constitutes an "independent sequence," as the P-pictures only refer to the preceding I-picture within the group. The "indication" of the first frame (the I-picture) is its I-picture reference address (IAD), which is set to zero. Kim's decoding process starts with the I-picture, even if a user requests a dependent P-picture, thus meeting the limitation of starting decoding from the first image frame. The "identifier value" is Kim’s "logical address," which is composed of a current address (CAD) and the IAD. Petitioner argued the IAD component is reset to zero for each I-picture that begins a new sequence, satisfying the "resetting" limitation. As with Ground 1, the hardware limitations of claims 10 and 11 were argued to be obvious implementations of Kim’s described decoder.
    • Motivation to Combine (for §103 grounds): Not applicable (single-reference ground).
    • Expectation of Success (for §103 grounds): Not applicable (single-reference ground).

Ground 3: Obviousness over MPEG-1 and Yagasaki - Claim 9 is obvious over MPEG-1 in view of Yagasaki.

  • Prior Art Relied Upon: MPEG-1 (ISO/IEC 11172-2) and Yagasaki (Patent 5,786,858).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon Ground 1 for the limitations of claim 8. Claim 9 further requires that the "indication is a separate flag included in the header of a slice." While MPEG-1 discloses the base method, Yagasaki was cited for teaching this specific limitation. Yagasaki describes improving high-speed playback in MPEG systems by adding a "structure flag" to the slice header. This flag indicates whether a slice is composed entirely of intra-coded macroblocks. Petitioner argued that a POSITA would recognize that a frame made up entirely of such slices is an I-frame, which serves as the beginning of an independent sequence. The flag in the slice header therefore functions as the claimed indication.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings because Yagasaki explicitly addresses improving the functionality of MPEG systems. Yagasaki’s flag provides an efficient way to identify intra-coded regions for the decoder, which is a known goal in video compression. Implementing Yagasaki's flag in an MPEG-1 system would have been a straightforward application to improve decoding efficiency.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because Yagasaki teaches that slices containing its flag can be decoded using the normal MPEG decoding process, ensuring compatibility and predictable results.

4. Key Claim Construction Positions

  • "indication": Petitioner argued that this term should be given its plain and ordinary meaning. This argument was presented to preemptively counter a construction proposed by the Patent Owner in a related proceeding, where the owner argued "indication" means "information...that necessarily confirms something to a decoder." Petitioner contended this adds an unsupported "conclusiveness" requirement and that the prior art meets the claim language even under the owner's narrower proposed construction.

5. Relief Requested

  • Petitioner requests inter partes review of claims 8-11 of the ’321 patent and cancellation of those claims as unpatentable.