PTAB

PGR2025-00083

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 ’452 patent discloses methods and systems for on-board assessment of picture quality in camera devices. The technology uses a processor to calculate multiple quality indicators (QIs) from image sensor data, combines them into a total quality indicator, and provides real-time suggestions to the user for improving photo quality, such as moving the device to a different location.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 2 are obvious over Anon, Takeuchi, and Garcia-Molina

  • Prior Art Relied Upon: Anon (Patent 8,508,622), Takeuchi (Application # 2010/0149361), and Garcia-Molina (a 2009 textbook on database systems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Anon, the primary reference, taught a camera system with a processor that determines image quality based on a "composition measure" derived from multiple image-based characteristics. This system provided real-time feedback and suggestions to the user, including suggestions to "move or reorient the camera." Petitioner contended Anon disclosed calculating quality indicators for a face/object (QI1) and aesthetic quality (QI2) and combining them into a total quality indicator. While Anon did not explicitly teach a "background blurring test," Petitioner argued Takeuchi disclosed this feature for image quality evaluation. Takeuchi’s blur/focus test, which evaluates background focus relative to the subject, was presented as a known technique for improving image quality. Finally, Anon disclosed using "rule sets" in "data structures" to store suggestions; Petitioner asserted that implementing these as a "pre-stored table," as claimed, was an obvious design choice, supported by the Garcia-Molina textbook, which identified tables as a prevalent and fundamental data model.
    • Motivation to Combine: A POSITA would combine Takeuchi’s background blur test with Anon’s system to enhance its focus analysis and improve overall image quality, as both references shared the common goal of comprehensive image evaluation. Implementing Anon's rule sets as a table using Garcia-Molina's teachings was a standard and predictable choice for efficient data storage and retrieval.
    • Expectation of Success: A POSITA would have an expectation of success because it involved applying a known image analysis technique (blur testing) to improve a known camera system and using a conventional data structure (a table) for a known purpose (storing rules).

Ground 2: Claim 3 is obvious over Anon, Takeuchi, and Garcia-Molina in view of Kosaka

  • Prior Art Relied Upon: Anon (Patent 8,508,622), Takeuchi (Application # 2010/0149361), Garcia-Molina (a 2009 textbook), and Kosaka (Application # 2004/0012682).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the combination for claim 1 to address the limitation in dependent claim 3, wherein the total quality indicator includes "testing the obstruction of at least one lens." Petitioner argued that Kosaka explicitly taught a digital camera system designed to detect if a user's finger or another object was unintentionally obstructing the lens before an image is captured. Kosaka’s system analyzed live-view images in real time to identify stationary low-brightness areas at the periphery, indicative of an obstruction, and notified the user.
    • Motivation to Combine: A POSITA would be motivated to integrate Kosaka's lens obstruction test into Anon's comprehensive quality assessment framework. Since both Anon and Kosaka aimed to improve image quality by identifying and correcting common photographic flaws, adding a known test for a frequent problem like lens obstruction was a logical and complementary enhancement to Anon’s system.
    • Expectation of Success: The combination was a straightforward integration of a specific feature-detection module (Kosaka) into a flexible, extensible quality analysis engine (Anon). A POSITA would expect predictable results, as Kosaka's binary output (obstruction/no obstruction) fits naturally as another weighted input into Anon's quality scoring engine.

Ground 3: Claims 5 and 10 are obvious over Anon, Takeuchi, and Garcia-Molina in view of Bigioi and Wakabayashi

  • Prior Art Relied Upon: The base combination for claim 1, plus Bigioi (Application # 2012/0133746) and Wakabayashi (Application # 2013/0076856).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed limitations in claims 5 and 10 related to 3D imaging, which required using two lens/sensor modules and building a 3D scene reconstruction. While Anon mentioned 3D photography as a possible application, it lacked implementation details. Petitioner argued Bigioi and Wakabayashi provided these missing elements. Both references taught using two lenses and sensors to capture stereoscopic images for creating 3D photographs. Bigioi further described creating a 3D scene, for example, to produce a "3D Bokeh effect" by aligning background regions and using disparity maps. Wakabayashi explicitly disclosed a device with distinct left and right lens/sensor pairs for capturing stereoscopic images.
    • Motivation to Combine: Given Anon’s express mention of 3D photography, a POSITA seeking to implement this feature would have been motivated to look to known stereoscopic techniques. Bigioi and Wakabayashi provided a well-understood path to enable 3D functionality in Anon's camera system, such as generating higher-quality 3D portraits or basing suggestions on a 3D scene reconstruction.
    • Expectation of Success: The combination involved incorporating established 3D capture and processing techniques into a system already contemplated for such use. A POSITA would expect success in adding this functionality to yield predictable improvements in 3D photography.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 4, 6-9, 11, and 12 based on further combinations including Li (for depth of field calculation), Ramesh (for using confidence levels), Liu (for fusing multiple algorithms), and Yang (for using deep learning). Petitioner also asserted that claims 5-8 are invalid for indefiniteness under §112, claim 4 lacks written description under §112, and all challenged claims (1-12) are invalid for claiming patent-ineligible subject matter under §101.

4. Key Technical Contentions (Beyond Claim Construction)

  • Disputed Priority Date: A central contention was that the ’452 patent was not entitled to its claimed priority dates from two 2012 and 2013 provisional applications. Petitioner argued that key limitations required by all challenged claims, such as "selecting... a suggestion from a pre-stored table of suggestions," were new matter not disclosed in the provisional applications. Therefore, Petitioner contended the patent’s effective priority date was after March 16, 2013, making it eligible for Post-Grant Review and rendering certain publications, such as Liu and Wakabayashi, available as prior art.

5. Relief Requested

  • Petitioner requests institution of Post-Grant Review and cancellation of claims 1-12 of the ’452 patent as unpatentable.