PTAB

IPR2025-01439

Snap Inc v. Nokia Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Coding Motion in a Video Sequence
  • Brief Description: The ’808 patent discloses methods for video encoding and decoding that redefine the "skip mode" concept. The invention associates a macroblock in skip mode with either a zero motion vector or a non-zero motion vector, where the selection depends on the motion characteristics of neighboring, previously coded segments to improve compression efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness over Karczewicz - Claims 1-2, 6-7, 9, 23-25, 28-30, 32, 34, 36, 39-41, 43, 65 are obvious over Karczewicz

  • Prior Art Relied Upon: Karczewicz (International Publication No. WO 01/11891 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Karczewicz teaches five coding modes for video segments, two of which collectively perform the function of the ’808 patent’s claimed "skip coding mode." One mode encodes a segment using only a "prediction field" derived from a neighboring segment (resulting in a non-zero motion vector), while another mode encodes the segment using a zero motion vector (ZMV). Petitioner asserted that Karczewicz teaches using a single bit indicator (the MCI bit) to signal both of these conditions. When the MCI bit is zero, it indicates that no refinement motion coefficients are transmitted, which is true for both the prediction-only mode and the ZMV mode.
    • Motivation to Combine (for §103 grounds): Although this is a single-reference ground, Petitioner argued a POSITA would have been motivated to understand these two distinct modes as a single, combined "skip mode" signaled by the zero MCI bit. Doing so would reduce complexity and improve coding efficiency by simplifying the number of available coding modes for the encoder and decoder, which aligns with the stated goals of video compression.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because Karczewicz already provided the mechanism (the MCI bit) to signal the combined functionality, requiring no technical modification beyond redefining the two modes as a single "skip mode."

Ground 2: Obviousness over MPEG-1 and H.263 - Claims 1-2, 6-7, 9, 23-25, 28-30, 32, 34, 36, 39-41, 43, 65 are obvious over MPEG-1 in view of H.263

  • Prior Art Relied Upon: MPEG-1 (ISO/IEC 11172-2:1993) and H.263 (ITU-T Recommendation H.263).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that MPEG-1 discloses "skipped macroblocks" where the motion vector for the current macroblock is simply copied from the immediately preceding macroblock. H.263, a later standard, teaches a more sophisticated method for predicting motion vectors based on the median value of motion vectors from three surrounding macroblocks (left, top, and top-right). Petitioner argued the combination of these references renders the claims obvious, as it would have been an obvious improvement to replace MPEG-1's simple, single-neighbor prediction for skipped macroblocks with H.263's more accurate, multi-neighbor median prediction. This combination would result in either a zero or a non-zero motion vector being assigned to the skipped macroblock, depending on the median of the surrounding motion vectors.
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references to improve the accuracy of motion prediction in skipped macroblocks, leading to better image quality and compression efficiency. By the time of the invention, advancements in processing power would have made the slightly more computationally intensive median prediction of H.263 an attractive and obvious replacement for the simpler method in MPEG-1.
    • Expectation of Success (for §103 grounds): The combination was a simple substitution of one known technique (MPEG-1's single-macroblock prediction) for another known, superior technique (H.263's median prediction) to achieve the predictable result of more accurate video coding.

4. Key Claim Construction Positions

  • "skip coding mode": Petitioner adopted the preliminary construction from a prior IPR involving the ’808 patent, which was also advocated for by the Patent Owner. The proposed construction is: "a coding mode in which a zero (non-active) motion vector or a non-zero (active) motion vector is associated with each skip mode macroblock, depending on the characteristics of the motion in image segments surrounding the macroblock in question." This construction is central to both grounds, as Petitioner argued the prior art teaches a mode that meets this definition by assigning a motion vector based on the motion of surrounding blocks.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 6-7, 9, 23-25, 28-30, 32, 34, 36, 39-41, 43, and 65 of the ’808 patent as unpatentable.