PTAB

IPR2025-01440

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 relates to video encoding systems and methods that improve "skip mode" techniques for motion compensated prediction. The patent discloses a redefined skip mode where a macroblock can be associated with either a zero motion vector or a predicted non-zero motion vector derived from the motion of neighboring macroblocks.

3. Grounds for Unpatentability

Ground 1: Claims 10-11, 15-16, 20-22, 44, 47-49, 51-54, 58-60, and 62-64 are obvious over Karczewicz.

  • Prior Art Relied Upon: Karczewicz (WO 01/11891 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Karczewicz, which teaches a video encoding apparatus with five distinct coding modes, discloses all limitations of the challenged claims. Petitioner asserted that two of Karczewicz's modes—one using a predicted motion vector from a neighbor (a non-zero vector) and another using a copy from a reference frame (a zero motion vector)—functionally constitute the claimed "skip coding mode." This assertion was based on Karczewicz's teaching of a single indicator bit (the Motion Coefficient Indication or MCI bit), which when set to zero, signals both of these scenarios. Petitioner identified Karczewicz's Motion Field Coder (MFC) as the claimed "coding controller" and "motion estimation block," as it selects the most efficient coding mode.
    • Motivation to Combine: Petitioner contended that to the extent Karczewicz's modes are viewed as separate, a person of ordinary skill in the art (POSITA) would have found it obvious to combine their functionalities into a single "skip mode." The motivation would be to reduce complexity and improve coding efficiency, especially since Karczewicz already teaches a single indicator to signal both outcomes.
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing this single mode because Karczewicz already provides the specific mechanism (the zero MCI bit) to signal the combined functionality, requiring no technical modification beyond a redefinition of the mode.

Ground 2: Claims 10-11, 15-16, 20-22, 44, 47-49, 51-54, 58-60, and 62-64 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 argued that MPEG-1 discloses a basic "skip mode" for macroblocks where the motion vector is either zero or copied from a single preceding macroblock. H.263 teaches a more advanced method for predicting motion vectors by calculating the median of motion vectors from three surrounding macroblocks. Petitioner asserted that the combination renders the claims obvious by modifying MPEG-1's simple skip mode to incorporate H.263's more robust median prediction technique. This combined system results in a skip mode where the assigned motion vector is the median of its neighbors, which can be either zero or a predicted non-zero vector depending on surrounding motion, thereby meeting the key limitations of independent claims 10 and 16. MPEG-1’s "Motion Estimator" was mapped to the claimed "motion estimation block."
    • Motivation to Combine: A POSITA would combine the references to improve the accuracy and coding efficiency of MPEG-1's skip mode. Using the median of three neighbors (from H.263) was a known technique for improving prediction accuracy compared to using a single neighbor (from MPEG-1). Petitioner argued that by the patent's priority date, advancements in processing power made this more computationally intensive but superior method an attractive and obvious improvement for any standard video codec.
    • Expectation of Success: Success was predictable because the combination involved the simple substitution of one known prediction element (MPEG-1's single-block method) for another known, superior one (H.263's median-based method) to obtain the well-understood and predictable result of more accurate video coding.

4. Key Claim Construction Positions

  • Petitioner's arguments relied on a specific construction for the term "skip coding mode" that was adopted by the Board in a previous inter partes review (IPR) involving the ’808 patent.
  • Petitioner applied the Board's preliminary construction, which the Patent Owner had previously accepted: "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 was central to mapping the prior art in both grounds.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 10-11, 15-16, 20-22, 44, 47-49, 51-54, 58-60, and 62-64 as unpatentable.