PTAB

IPR2025-01520

Samsung Electronics America Inc v. SnapAid Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Real Time Assessment of Picture Quality
  • Brief Description: The ’702 patent describes a method and system for the real-time assessment of picture quality in camera devices. The system uses data from various sensors, such as accelerometers and lens modules, to determine a plurality of quality indicators (QIs) and provides real-time suggestions to a user for improving photo quality.

3. Grounds for Unpatentability

Ground 1: Obviousness over Anon, Suzuki, and Garcia-Molina - Claims 11-13 and 17-19 are obvious over Anon in view of Suzuki and Garcia-Molina.

  • Prior Art Relied Upon: Anon (Patent 8,508,622), Suzuki (Patent 5,831,670), and Garcia-Molina (a 2009 textbook on database systems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Anon taught the foundational camera system, which uses an accelerometer and analyzes image characteristics to provide real-time compositional feedback to a user. To the extent Anon did not explicitly teach obtaining a value responsive to the "device angle to the horizon," Petitioner asserted Suzuki supplied this teaching by disclosing a system that analyzes camera inclination and provides corrective feedback for tilt. Both Anon and Suzuki were cited for using thresholds to trigger user suggestions. Garcia-Molina was introduced to establish that implementing Anon’s disclosed “rule sets” within a pre-stored “table” was a well-known and obvious design choice for data storage and retrieval.
    • Motivation to Combine: A POSITA would combine Anon and Suzuki to improve Anon’s general-purpose composition engine with Suzuki's specific solution for correcting camera tilt, a common cause of poor photographic aesthetics. This integration would be a natural extension of Anon's stated goal of providing comprehensive feedback to help users capture better-composed images.
    • Expectation of Success: Petitioner asserted success was predictable because both systems are designed to process sensor data to provide user guidance. Suzuki’s tilt-correction methods were argued to be fully compatible with Anon’s flexible and extensible software architecture.

Ground 2: Obviousness over Anon, Walker, Kosaka, Jasinski, and Garcia-Molina - Claims 1-3, 5, and 7-10 are obvious over Anon in view of Walker, Kosaka, Jasinski, and Garcia-Molina.

  • Prior Art Relied Upon: Anon (Patent 8,508,622), Walker (Application # 2008/0192129), Kosaka (Application # 2004/0012682), Jasinski (Application # 2012/0201427A1), and Garcia-Molina (a 2009 textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner alleged this combination built upon Anon's base system by adding several discrete quality metrics. Walker was cited for teaching the calculation of a quality value for image exposure (QI2), including specific analysis of facial exposure. The combination of Anon and Walker was argued to teach face detection and the analysis of facial properties like "looking at camera" (QI3). Kosaka was asserted to provide the teaching for detecting lens obstruction and generating a corresponding quality value (QI4). Jasinski was introduced to supply the teaching of dynamically estimating the weights for each quality indicator based on real-time image data, rather than using fixed weights. Garcia-Molina was again cited to support the obviousness of using a "table" to store suggestions.
    • Motivation to Combine: A POSITA would combine these references to create a more comprehensive and robust image quality assessment tool. Petitioner argued that because Anon’s system was designed to be extensible, adding well-understood quality metrics for exposure (Walker) and lens obstruction (Kosaka) would be a straightforward improvement. Incorporating Jasinski's dynamic weighting would improve the accuracy of the final quality score by allowing the system to adapt to changing scene conditions and the relative importance of different factors.
    • Expectation of Success: Success was expected because the references are complementary. The quantitative outputs from Walker (exposure rating) and Kosaka (obstruction value) are modular inputs that fit naturally into Anon's weighted evaluation framework. Using a known technique like dynamic weighting (Jasinski) to improve a system that combines multiple data sources (Anon) would yield predictable results.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on variations of the above combinations. These grounds primarily added single references to address specific dependent claim limitations, such as adding Ramesh (Application # 2009/0296989) for associating quality values with an estimated error, Liu (an IEEE 2012 publication) for using multiple aesthetic algorithms, and Cheatle (Application # 2002/0110286A1) for using a pre-stored list of faces for recognition.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’702 patent as unpatentable.