PTAB

IPR2026-00181

Google LLC v. Clear Imaging Research LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and apparatus to correct digital video to counteract effect of camera shake.
  • Brief Description: The ’450 patent discloses methods for correcting for camera shake in digital video. The technology involves using motion sensors to detect camera movement during image capture and then processing the images based on the detected motion to produce a stabilized final video.

3. Grounds for Unpatentability

Ground 1: Claims 1-26 and 28-32 are obvious over Dutta in view of Akifumi.

  • Prior Art Relied Upon: Dutta (Application # 2003/0076408) and Akifumi (Japanese Application # 2000-023024).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dutta disclosed a handheld imaging device with an image sensor, motion sensors, a processor, and memory. Dutta’s device captured a sequence of images, detected device motion, and used that motion information to correct and combine the images. However, Dutta did not explicitly apply this to video or detail the correction mechanism. Akifumi supplied the missing elements by teaching an image inputting device for video that used motion sensors (e.g., acceleration sensors) to calculate vertical and horizontal shift values. Akifumi then applied these shift values to correct images stored in frame memory, explicitly teaching video compression and storage of the final stabilized video.
    • Motivation to Combine: A POSITA would combine Akifumi’s video stabilization and compression techniques with Dutta’s handheld device to improve its functionality. Dutta’s device was capable of capturing sequential images, and applying Akifumi’s teachings would be a straightforward way to produce a stabilized, compressed final video, a desirable feature for a portable device with limited storage.
    • Expectation of Success: A POSITA would have a reasonable expectation of success as the combination involved applying known video stabilization techniques (from Akifumi) to a similar imaging system (Dutta) to achieve the predictable result of a handheld device that produces stabilized video.

Ground 2: Claims 13, 26, and 32 are obvious over Dutta in view of Akifumi and Creative Camcorder.

  • Prior Art Relied Upon: Dutta (Application # 2003/0076408), Akifumi (Japanese Application # 2000-023024), and Creative Camcorder (an article from Popular Electronics, Mar. 1996).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Dutta and Akifumi combination to address the user input limitations of claims 13, 26, and 32. Petitioner asserted that Creative Camcorder, which described a Canon video camera, disclosed a user interface with an LCD viewfinder that displayed icons indicating whether image stabilization was active. This taught providing user input via buttons or a joystick to turn the stabilization feature on or off.
    • Motivation to Combine: A POSITA would be motivated to add the user-controlled stabilization feature from Creative Camcorder to the Dutta-Akifumi device. This would improve the base device by giving the user direct control over the stabilization process, which could be used to conserve battery life by disabling the computationally intensive feature when not needed.
    • Expectation of Success: Success would be expected because adding a user-selectable on/off toggle for a specific software feature was a well-known design choice for electronic devices and would not require any undue experimentation to implement.

Ground 3: Claim 27 is obvious over Dutta in view of Akifumi and Balmer.

  • Prior Art Relied Upon: Dutta (Application # 2003/0076408), Akifumi (Japanese Application # 2000-023024), and Balmer (Patent 5,881,272).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed the limitation of claim 27 requiring "two or more processors." Petitioner argued that Balmer disclosed a multi-processing system specifically designed for image and video processing. Balmer taught that using multiple synchronous processors provided additional computing power and faster calculation times, identifying imaging systems as "prime candidates for multi-processing."
    • Motivation to Combine: A POSITA would implement the processing engine of the Dutta-Akifumi device using a multi-processor architecture as taught by Balmer. The motivation was to improve performance for the computationally intensive tasks of real-time video stabilization and compression, resulting in a more efficient and powerful device.
    • Expectation of Success: The combination would yield predictable results. As Balmer confirmed, using parallel processors for image processing was a well-known technique to improve speed, and a POSITA would have reasonably expected success in applying this established architecture to the Dutta-Akifumi system.

4. Key Claim Construction Positions

  • "a processor configured to..." / "...by the processor...": Petitioner argued these terms, which appear in most challenged claims, should be given their plain and ordinary meaning. However, Petitioner contended that if the Board determines these are means-plus-function terms under §112, the only corresponding structure disclosed in the ’450 patent is an integrated circuit or processor(s). Petitioner asserted that under either construction, the prior art combinations disclosed the necessary structure and performed the claimed functions.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. A prior IPR filed by Samsung on the ’450 patent (IPR2020-01394) was denied institution under the Fintiv factors. Therefore, the Board has never previously reached a decision on the substantive merits of the invalidity arguments against the challenged claims.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-32 of the ’450 patent as unpatentable.