PTAB

IPR2025-01338

Snap Inc v. Nokia Technologies Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for coding sequences of pictures
  • Brief Description: The ’818 patent discloses a method for encoding and decoding video data by splitting parameters into a hierarchical structure. The claimed invention separates parameters into a "sequence parameter set," a "picture parameter set," and embeds at least one picture parameter value directly into a "slice header" to improve coding efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-23 over Au

  • Prior Art Relied Upon: Au (Patent 6,646,578).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Au, a single prior art reference related to the H.264 video standard, teaches every element of the challenged claims. Au allegedly disclosed the same hierarchical system for video coding, including a "sequence parameter set" with values that remain unchanged for an entire video sequence, a "picture parameter set" with values that remain unchanged for a single picture, and a "slice header." Critically, Petitioner asserted that Au's slice header explicitly contains a "frame_num" (frame number), which is a picture parameter value that remains unchanged across all slice headers of a single picture to enable proper reconstruction of the frame. Petitioner contended this disclosure maps directly to the core limitations of the ’818 patent’s independent claims. Dependent claims were argued to be obvious as they recite additional conventional features of video coding also disclosed by Au, such as referencing parameter sets by including an identifier in a lower-level header.

Ground 2: Obviousness of Claims 1-23 over VCEG-N52 in view of Sriram

  • Prior Art Relied Upon: VCEG-N52 (H.26L over IP and H.324 Framework) and Sriram (Patent 6,539,059).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that VCEG-N52, which the ’818 patent acknowledged as disclosing the foundational "Parameter Set Concept," provides the baseline system for transmitting video coding parameters. However, VCEG-N52 described a more monolithic parameter set. Sriram was argued to remedy this by teaching a system designed for efficiency that explicitly uses "several smaller data structures" for parameters extracted from different levels of the video hierarchy (sequence, Group of Pictures (GOP), and picture). The combination allegedly rendered it obvious to split VCEG-N52's general parameter set into the specific hierarchical sets claimed in the ’818 patent. For the limitation of a picture parameter value in the slice header, Petitioner argued that VCEG-N52 discloses a "PictureID" in the slice header and that Sriram’s teachings on the applicable H.263 standard confirm that such an identifier remains the same for all slices in a picture.
    • Motivation to Combine: A POSITA would combine the teachings of VCEG-N52 and Sriram to improve the efficiency and reduce the bandwidth of the VCEG-N52 system. Sriram’s explicit goal was to enhance efficiency by creating separate, hierarchical data structures for parameters. A POSITA would have been motivated to apply this established principle to VCEG-N52's parameter set framework to avoid repeating high-level (e.g., sequence) parameters in every picture-level transmission, thereby achieving the shared goal of both references.
    • Expectation of Success: A POSITA would have had a high expectation of success because combining the references would involve applying Sriram’s known data structuring techniques to VCEG-N52’s parameter set concept. This was presented as a routine software engineering task that would predictably result in a more efficient video coding system without requiring undue experimentation.

4. Key Claim Construction Positions

  • Petitioner contended that no special claim constructions were necessary to resolve the issues presented.
  • Means-Plus-Function (MPF): For claims 22 and 23, which recite "means for" limitations, Petitioner identified the corresponding structures from the ’818 patent specification as required. For the "means for" limitations in encoder claim 22, Petitioner identified the structure as "an encoder as described in the ’818 patent specification in figure 3 and equivalents thereof." For the "means for" limitations in decoder claim 23, the structure was identified as "a decoder as described in the ’818 patent specification in figure 4 and equivalents thereof." Petitioner argued that the asserted prior art teaches these corresponding structures or their equivalents.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-23 of the ’818 patent as unpatentable under 35 U.S.C. §103.