PTAB

IPR2025-01520

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 ’702 patent describes a method and system for the real-time assessment of picture quality in camera devices. The system uses data from multiple sensors (e.g., accelerometers, lens modules) to determine a plurality of quality indicators (QIs) which are then combined to provide users with real-time feedback and suggestions for improving photo quality.

3. Grounds for Unpatentability

Ground 1: 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 core method of independent claim 11: a camera device with an image sensor, motion sensor (accelerometer), and processor that estimates image quality by analyzing multiple image characteristics and providing real-time feedback. However, to the extent Anon did not explicitly teach obtaining a value responsive to the "device angle to the horizon," Suzuki supplied this limitation by disclosing a camera system that analyzes camera tilt, calculates deviation values from the horizontal, and provides corrective feedback. For the limitation of selecting suggestions from a "pre-stored table," Petitioner argued that while Anon taught using "rule sets" in "data structures," Garcia-Molina established that using a table is the most common and obvious data structure for such a purpose.
    • Motivation to Combine: A POSITA would combine Anon and Suzuki to improve a common photographic flaw—unintentional camera tilt. Integrating Suzuki’s well-known tilt-detection and correction feature into Anon’s extensible real-time feedback system would have been a natural and predictable improvement. Further, a POSITA would have been motivated to implement Anon's "rule sets" using a standard table structure as taught by Garcia-Molina for efficient data storage and retrieval, which represents a simple application of a known technique to improve a similar device.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination because both Anon and Suzuki are camera systems designed to provide user guidance. Integrating Suzuki's tilt analysis as another input into Anon's weighted parameter system would have been a straightforward engineering task.

Ground 2: 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 # 2012/0201427), and Garcia-Molina (a 2009 textbook).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that this combination rendered claims 1-3, 5, and 7-10 obvious. Anon again provided the foundational system for real-time quality assessment using motion/location sensors. Walker taught obtaining a second quality indicator (QI2) for under/over exposure, including for specific portions of an image like a face. Walker also taught obtaining a third quality indicator (QI3) by using face detection to determine properties like whether a subject is looking at the camera. Kosaka taught obtaining a fourth quality indicator (QI4) by detecting lens obstruction (e.g., by a finger) in real-time. Finally, Jasinski taught dynamically estimating the weights of various quality parameters based on a time-dependent confidence level.
    • Motivation to Combine: A POSITA would combine these references to create a more comprehensive and robust image quality assessment system. Integrating Walker’s exposure analysis and face detection and Kosaka’s obstruction detection would provide crucial inputs for Anon's holistic quality engine, addressing fundamental and common image defects. Anon’s system was designed to be extensible, and these features represented logical additions. A POSITA would incorporate Jasinski's dynamic, time-dependent weighting to improve the accuracy of the combined quality score by adapting to changing scene conditions and sensor reliability, rather than relying on static weights.
    • Expectation of Success: The modular nature of these image analysis techniques would have made their integration predictable. The quantitative outputs from Walker (exposure rating) and Kosaka (obstruction signal) are readily usable as weighted inputs in Anon's engine.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on variations of the core combinations above. These grounds added references like Ramesh (Application # 2009/0296989) to teach associating an estimated error with quality values, Liu (a 2012 IEEE article) for fusing scores from multiple aesthetic algorithms, and Cheatle (Application # 2002/0110286) for using a pre-stored database of facial features for recognition.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: Petitioner argued that the ’702 patent was not entitled to the priority dates of its provisional applications (filed in 2012 and 2013). Petitioner contended that neither provisional application provided written description support for key limitations required by all challenged claims, such as selecting "at least one appropriate suggestion from a pre-stored table of suggestions." As a result, certain references, such as Liu (published March 2013), qualified as prior art against the challenged claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 11,671,702 as unpatentable under 35 U.S.C. §103.