PTAB

IPR2025-01519

Samsung Electronics America, Inc. v. SnapAid, Ltd.

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1. Case Identification

2. Patent Overview

  • Title: Real Time Assessment of Picture Quality
  • Brief Description: The ’901 patent describes a method and system for real-time assessment of image quality in camera devices. The system uses multiple sensors, such as accelerometers and lens modules, to determine various quality indicators (QIs) which are then combined to evaluate the total image quality and provide feedback to the user.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 6, and 8 are obvious over Anon in view of Suzuki, Jasinski, and Garcia-Molina.

  • Prior Art Relied Upon: Anon (Patent 8,508,622), Suzuki (Patent 5,831,670), Jasinski (Application # 2012/0201427), and Garcia-Molina (a 2009 textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Anon taught the foundational system of independent claim 1: a camera device with an image sensor, lens, and processor that estimates image quality based on multiple characteristics and provides real-time suggestions. To the extent Anon’s disclosure of using an accelerometer for "orientation" was insufficient, Suzuki was cited for its explicit teaching of detecting camera tilt relative to the horizon and providing corrective feedback. To address the limitation of "estimating" a weight, Jasinski was introduced for its disclosure of dynamically calculating weights for image regions based on current scene conditions. Finally, to meet the "pre-stored table of suggestions" limitation, Petitioner argued that Anon’s "rule sets" stored in "data structures," in view of the Garcia-Molina textbook, would have been obviously implemented as a table, a common and efficient data structure.
    • Motivation to Combine: A POSITA would combine Anon's general image feedback system with Suzuki's specific tilt-detection feature to address unintentional camera tilt, a common cause of poor composition. A POSITA would incorporate Jasinski's dynamic weighting to make Anon's system more adaptive and accurate by allowing it to respond to changing scene conditions. Implementing Anon’s rule sets as a table, as suggested by Garcia-Molina, was presented as a standard design choice for efficient data management.
    • Expectation of Success: The combination involved applying known techniques (tilt correction, dynamic weighting) to an extensible base system (Anon) for their intended purposes. The modular nature of these image processing techniques ensured they could be integrated predictably.

Ground 2: Claims 10, 13-14, and 17-20 are obvious over Anon in view of Takeuchi, Jasinski, Kosaka, and Garcia-Molina.

  • Prior Art Relied Upon: Anon (Patent 8,508,622), Takeuchi (Application # 2010/0149361), Jasinski (Application # 2012/0201427), Kosaka (Application # 2004/0012682), and Garcia-Molina (a 2009 textbook).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targets claims related to independent claim 10, which is directed to estimating quality from a video stream. Petitioner asserted that Anon taught applying its methods to video. The combination adds Takeuchi and Kosaka to meet limitations specific to claim 10. Takeuchi was used to teach obtaining a quality value based on a measurement of under or over exposure, a fundamental aspect of image quality that Anon addresses more generally with "brightness." Kosaka was used to teach obtaining a quality value responsive to the obstruction of an optical lens, such as by a user's finger. The roles of Jasinski and Garcia-Molina remained the same as in Ground 1, addressing dynamic weight estimation and the use of a pre-stored table of suggestions, respectively.
    • Motivation to Combine: A POSITA would be motivated to enhance Anon's comprehensive image quality system by incorporating specific, well-known quality metrics. Adding Takeuchi’s robust exposure analysis and Kosaka’s lens obstruction detection would create a more complete and useful tool for photographers and videographers by flagging common, high-impact image flaws.
    • Expectation of Success: Petitioner contended that since Anon's system was designed to be extensible and accept multiple image-based inputs, integrating additional quality modules for exposure (Takeuchi) and obstruction (Kosaka) would be a straightforward and predictable extension of the system's architecture.

  • Additional Grounds: Petitioner asserted numerous other obviousness challenges targeting the remaining claims. These grounds relied on similar combinations, adding specific references to teach further limitations. Key additions included:

    • Ramesh (Application # 2009/0296989) was combined to teach associating weights with an estimated error (claim 5) and using probability distribution functions (claim 7).
    • Liu (a 2012 IEEE publication) was combined to teach fusing scores from multiple aesthetic algorithms, including a Peak Signal-to-Noise Ratio (PSNR) calculation (claims 9 and 11).
    • Alhadef (Patent 8,009,198) was combined to teach estimating weights for motion sensors based on sensor-specific error metrics like precision error and drift to compensate for inaccuracies (claim 15).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’901 patent as unpatentable.