PTAB

IPR2026-00192

Amazon.com Services LLC v. InterDigital Inc

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Petition

1. Case Identification

2. Patent Overview

  • Title: Methods and Apparatus for Improved Intra Chroma Encoding and Decoding
  • Brief Description: The ’606 patent discloses methods for video encoding and decoding that build upon the H.264 standard. The technology is directed to determining the size of blocks ("partitions") for encoding color information (chroma) based on the size of partitions used for encoding brightness information (luma).

3. Grounds for Unpatentability

Ground 1A: Obviousness over Sekiguchi and VCEG-AJ21 - Claims 1-3, 5, 10, 12, 14, 16, 18-19 are obvious over Sekiguchi in view of VCEG-AJ21.

  • Prior Art Relied Upon: Sekiguchi (Application # 2008/0170615) and VCEG-AJ21 (a printed publication publicly available by October 8, 2008).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sekiguchi teaches a video encoding system compatible with the H.264 standard that uses separate intra prediction modes for luma and chroma components. Sekiguchi discloses determining a chroma partition type based on a corresponding luma partition type, using partition sizes of 4x4, 8x8, and 16x16. Crucially, Sekiguchi teaches that only the luma partition type is signaled to the decoder to improve efficiency. VCEG-AJ21 was a proposal to extend the H.264 architecture to larger macroblock sizes for high-definition video, including 32x32 luma partitions and corresponding 16x16 chroma partitions. Petitioner asserted the combination of Sekiguchi's method with VCEG-AJ21's larger block sizes teaches all limitations of the independent claims, including performing intra prediction with multiple partition types for chroma (16x16, 8x8, 4x4), where the set of chroma partition types is different from the set of luma partition types (which also includes 32x32).
    • Motivation to Combine: Petitioner contended a POSITA would combine these references to improve video compression efficiency. A POSITA would have been motivated to apply the efficiency gains from Sekiguchi's method of separate luma/chroma prediction to the larger, more efficient macroblock sizes taught by VCEG-AJ21, which were specifically designed for high-resolution video. Both references build on the same H.264 standard, making them compatible.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success, as the combination would involve only routine engineering tasks, such as modifying the software of Sekiguchi’s system to incorporate the larger partition sizes from VCEG-AJ21. This modification would yield the predictable result of more efficient encoding for larger block sizes.

Ground 1B: Obviousness over Sekiguchi, VCEG-AJ21, and H.264 - Claims 4, 6, 11, 13, 15, 17, 20 are obvious over Sekiguchi in view of VCEG-AJ21 and H.264.

  • Prior Art Relied Upon: Sekiguchi (Application # 2008/0170615), VCEG-AJ21 (a 2008 printed publication), and H.264 (ITU-T Recommendation, Nov. 2007).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds the H.264 standard to the combination of Ground 1A to address dependent claims. For claims requiring selection of a "largest-size available transform" (e.g., claim 4), Petitioner argued H.264 discloses a single 4x4 transform for chroma in the 4:2:0 format. For the partition types taught by the primary combination, this 4x4 transform would be the largest available. For claims requiring the luma partition type to be "absolutely coded" (e.g., claim 6), Petitioner asserted H.264 provides a syntax (using mb_type and transform_size_8x8_flag fields) that encodes the luma partition type directly, without reference to neighboring blocks.
    • Motivation to Combine: A POSITA implementing the system of Sekiguchi and VCEG-AJ21 would naturally look to the underlying H.264 standard—which both primary references expressly build upon—to provide standard functionalities like transform selection and syntax for encoding partition information.

Ground 2A: Obviousness over Xiong and VCEG-AJ21 - Claims 1-3, 5, 10, 12, 14, 16, 18-19 are obvious over Xiong in view of VCEG-AJ21.

  • Prior Art Relied Upon: Xiong (WO 2006/026903) and VCEG-AJ21 (a 2008 printed publication).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Xiong as an alternative to Sekiguchi, arguing it also teaches a method to improve chrominance coding efficiency by determining the chroma block size based on the luma block size. Xiong discloses using an 8x8 chroma block when a 16x16 luma block is used, and smaller 4x4 chroma blocks otherwise. Like Sekiguchi, Xiong teaches that this correspondence obviates the need to signal the chroma partition type. When combined with VCEG-AJ21's disclosure of larger 32x32 luma and 16x16 chroma partitions, the combination teaches the claimed system of determining a chroma partition type in response to a luma partition type, where the available partition sets for luma and chroma are different.
    • Motivation to Combine: The motivation is parallel to Ground 1A. A POSITA would combine Xiong's efficiency-improving method with VCEG-AJ21's larger macroblocks to achieve better compression performance for high-definition video, a known goal in the art at the time.
    • Expectation of Success: Success would be predictable because the combination would involve routine modification of Xiong's system to account for the additional, larger block sizes taught by VCEG-AJ21.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 4, 6, 11, 13, 15, 17, and 20 over the combination of Xiong, VCEG-AJ21, and H.264, relying on similar arguments regarding transforms and absolute coding as presented in Ground 1B.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. The petition noted that while a parallel district court litigation exists, the patent owner's complaint had not yet been served on the Petitioner as of the IPR filing date. This early stage of the co-pending litigation weighs strongly against denial under the Fintiv factors.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 10-20 of the ’606 patent as unpatentable.