UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`Google Inc.
`Petitioners,
`
`v.
`
`Vedanti Systems Limited
`
`Patent Owner.
`
`____________
`
`Case No. IPR2016-00212
`
`Patent No. 7,974,339
`____________
`
`PATENT OWNER VEDANTI SYSTEMS LIMITED’S PRELIMINARY
`RESPONSE
`UNDER 35 U.S.C. § 313 and 37 C.F.R. § 42.107
`
`
`
`
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`Google Inc.
`Petitioners,
`
`v.
`
`Vedanti Systems Limited
`
`Patent Owner.
`
`____________
`
`Case No. IPR2016-00212
`
`Patent No. 7,974,339
`____________
`
`PATENT OWNER VEDANTI SYSTEMS LIMITED’S PRELIMINARY
`RESPONSE
`UNDER 35 U.S.C. § 313 and 37 C.F.R. § 42.107
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`INTRODUCTION ............................................................................. 1
`
`OVERVIEW OF THE ‘339 PATENT ................................................ 1
`
`
`
`I.
`
`II.
`
`III. CLAIM CONSTRUCTION ............................................................. 11
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`“Frame Data” ......................................................................... 12
`
`“Region and Matrix” .............................................................. 13
`
`“Region Data/Matrix Data/Matrix Definition
`Data/Optimized Matrix Data” ................................................ 14
`
`“Matrix Size Data” ................................................................. 17
`
`“Pixel Variation Data” ........................................................... 18
`
`“Pixel Selection Data”/“Selection Pixel Data” ....................... 18
`
`IV. OVERVIEW OF THE PRIOR ART ................................................ 20
`
`A. Overview of Spriggs .............................................................. 20
`
`B.
`
`Overview of Golin ................................................................. 21
`
`V.
`
`SINCE THE PRIOR ART DOES NOT RENDER ANY
`CLAIM OBVIOUS, NO INTER PARTES REVIEW
`SHOULD BE INITIATED ............................................................... 22
`
`A.
`
`Because Petitioner conflates the terms “region
`data” and “pixel data,” the Petitioner has failed to
`show that the prior art teaches “a pixel selection
`system” that receives “region data” and generates
`“pixel data” for each region according to claim 1
`and therefore, Petitioner has failed to establish a
`prima facie case of obviousness for claims 1, 6,
`and 13. ................................................................................... 22
`
`
`
`i
`
`
`
`B.
`
`C.
`
`As found for the “selection system” of claim 1, the
`Petitioner has failed to show that the prior art
`teaches “selecting one of two or more sets of pixel
`data based on the optimized matrix data”
`according to claim 7 and therefore, Petitioner has
`failed to establish a prima facie case of
`obviousness for claims 7 and 9. .............................................. 27
`
`As found for the “selecting” step of claim 7, the
`Petitioner has failed to show that the prior art
`teaches “selecting a set of pixel data from each
`region according to claim 10 and therefore,
`Petitioner has failed to establish a prima facie case
`of obviousness for claims 10 and 12. ...................................... 29
`
`VI. CONCLUSION ................................................................................ 30
`
`
`
`ii
`
`
`
`
`
`
`
`TABLE OF AUTHORITIES
`
`
`
`Cases
`
`In re Cortright, 165 F.3d 1353, 1358 (Fed. Cir. 1999) ............................... 12
`
`In re NTP, Inc., 654 F.3d 1279, 1288 (Fed. Cir. 2011) ............................... 12
`
`In re Suitco Surface, Inc., 603 F.3d 1255, 1260 (Fed. Cir. 2010) ................ 11
`
`Microsoft Corp. v. Proxyconn, Inc., 789 F.3d 1292, 1297-1298
`(Fed. Cir. 2015) ....................................................................................... 11
`
`Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en
`banc) ....................................................................................................... 11
`
`Statutes
`
`35 U.S.C. § 314 ............................................................................................ 1
`
`
`
`Regulations
`
`37 C.F.R. § 42.100(b) ................................................................................. 11
`
`
`
`iii
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`Patent Owner Vedanti Systems Limited (“Vedanti” or “Patent
`
`Owner”) respectfully requests that the Board decline to initiate inter partes
`
`review of claims 1, 6, 7, 9, 10, 12 and 13 of U.S. Patent No. 7,974,339 (the
`
`“‘339 Patent”) because Petitioner Google Inc., (“Petitioner”) has failed to
`
`show that it has a reasonable likelihood of prevailing with respect to any of
`
`the challenged claims. 35 U.S.C. § 314.
`
`Petitioner has submitted proposed grounds for challenge based on
`
`obviousness. To establish obviousness, Petitioner must show that the
`
`references teach all of the elements of the claimed combination. The present
`
`petition fails to present a reasonable likelihood of establishing obviousness
`
`because for each proposed ground at least one claim element is missing from
`
`the relied-upon combination of references.
`
`
`
`II. OVERVIEW OF THE ‘339 PATENT
`The ‘339 Patent is directed to, among other things, to systems and
`
`methods for reducing the amount of frame data to be transmitted between a
`
`first transmitting location and a second receiving location through a
`
`communications medium such as the Internet, optical or wireless networks.
`
`Exhibit 1001, col. 1 lines 32-33; col. 2 lines 60-63. The transmitted frame
`
`
`
`1
`
`
`
`data may be any data type, such as, for example, video data, audio data,
`
`graphical data, or text data. Id. at, col. 1 lines 42-44 and lines 50-51. An
`
`advantage of the patented data transmission system and methodology is that
`
`it reduces data transmission requirements by eliminating data from a frame
`
`that is not required for the application of the data on the receiving end. Id. at
`
`col. 1, lines 53-60. This can be accomplished by determining the optimal
`
`frame data to be transmitted based on the use of the frame at the receiver.
`
`For example, if the frame data is an image, data of high detail may be
`
`transmitted in a lossless form and data of low detail may be transmitted in a
`
`lossy form so as to maintain the overall image quality for human perception.
`
`Id. at Col.1 line 36-39, Col. 4 line 66 – Col. 5 line 2, Col. 6 lines 17-24 and
`
`
`
`2
`
`
`
`Col. 9 lines 1-4.
`
`
`
`Fig. 1 of the ‘339 patent shows the core components of the
`
`transmission system and the receiving system of an exemplary embodiment
`
`of the invention. The data transmission system includes a frame analysis
`
`system 106 for receiving frame data and generating region data that divides
`
`the frame into a number of regions. The regions may be of an arbitrary size
`
`and shape and the regions are determined based on the information content
`
`of the data contained within a frame. The data transmission system also
`
`includes a pixel selection system 108 that receives the region data and
`
`generates a set of pixel data for each region. At least one original pixel from
`
`
`
`3
`
`
`
`each region is selected and the optimized frame data including region data
`
`defining the size shape and location of each region and the corresponding
`
`pixel data for each region is transmitted from the first location to the second
`
`location. Id at col. 2 lines 65-67
`
`On the receiving side, the computer implemented processes and data
`
`receiving system include a pixel data system 110 and a display generation
`
`system 112. The data receiving system receives the optimized frame data
`
`from the data transmission system and generates a display for a user that
`
`utilizes the optimized frame data including the region data and pixel data
`
`transmitted by the transmission system. Id. at Col. 3 lines 35-40.
`
`For an exemplary embodiment, Figs. 2 and 3 further explain the
`
`processes performed by the frame analysis system and the pixel selection
`
`system of the data transmission system while Fig. 4 further explains the
`
`processes performed by the pixel data system that is part of the data
`
`receiving system.
`
`
`
`4
`
`
`
`
`
` As shown in Fig. 2 above, the frame analysis system of the data
`
`transmission system further includes additional components including a
`
`pixel variation system, a matrix size system and a matrix identification
`
`system. Id. at Col. 5 lines 12-20. The pixel variation system 202 determines
`
`the level of detail required based on variations in pixel data. The pixel
`
`variation system 202 compares two adjacent pixels to determine whether the
`
`amount of variation between the pixels exceeds a predetermined tolerance,
`
`such as the amount of pixel data required to transmit the image data for
`
`perception. Id. at col. 5 lines 21-32 The pixel variation system 202 can have
`
`a number of tolerance settings so that the matrix size, region size or other
`
`data optimization set can be determined. Id.
`
`The matrix size system 204 generates matrix size data based on the
`
`pixel variation data from the pixel variation system 202. The matrix size
`
`system 204 can generate matrix shapes with non-symmetrical dimension
`
`data such as an NxM matrix, wherein N and M are not equivalent as well as
`
`amorphous region data, circular region data, and elliptical region data or
`
`other suitable region based on the pixel variation data. Id. at col. 5 lines 60-
`
`63. Additionally, the matrix size system can generate matrix control data,
`
`such as where a non-uniform matrix or region size is used within a frame. Id.
`
`at 64-66. Thus, the matrix size system can generate an optimized region for
`
`
`
`5
`
`
`
`sets of pixels based upon the information contained in the pixels as
`
`identified by the pixel variation system and does not begin with
`
`predetermined regions. By not having predetermined region shapes and
`
`instead basing the regions on the information contained within the data, each
`
`region conforms to the shape represented by the data and can therefore, be
`
`amorphous in shape.
`
`Matrix identification system 206 receives matrix size data and
`
`generates matrix identification data. Id. at col. 6 line 4-5. Matrix
`
`identification system can identify whether a uniform matrix size is being
`
`generated, the number of matrices within a frame, the sequence data for the
`
`matrices when in a non-uniform matrix. Id. at col. 6 lines 5-13. The matrix
`
`identification system 206 generates matrix identification data for use by data
`
`receiving system 104 to allow the generation of the optimized display of the
`
`data. Id. at col. 6 lines 13-16.
`
`
`
`
`
`6
`
`
`
`The pixel selection system of Fig. 1 is shown in more detail in Fig. 3
`
`provided above. In one embodiment of the invention, the system includes a
`
`pixel randomizer system 302, a pixel sequencer system 304 and a pixel
`
`identification system 306. Pixel randomizer system 302 selects a pixel from
`
`within each region for transmission. The pixel sequence system 304
`
`determines the order in which the pixels from each region will be
`
`transmitted based upon their position within the data frame. The pixel
`
`identification system 306 generates pixel identification data to identify the
`
`pixel that should be illuminated in the display at the receiver for each of the
`
`regions. Thus, the pixel identification system provides coordinates of the
`
`pixels to be illuminated for the regions.
`
`
`
`
`
`Fig. 4 shows the additional components that are within the pixel data
`
`system 110 of the data receiver system 104 including the matrix definition
`
`system 402 and the pixel location system 404. The matrix data and the pixel
`
`
`
`7
`
`
`
`data are transmitted to the data receiver system. Id. Col. 7 lines 63-64. The
`
`matrix definition system 402 is used for generating frame data from the
`
`received matrix data or region data for shapes such as ellipses, circles,
`
`amorphous shapes or other suitable shapes See Id. col. 7 lines 25-27. Thus,
`
`the matrix definition system receives as input the locations and sizes/shapes
`
`of each matrix/region that make up the frame of data. The pixel location
`
`system 404 receives as input the location of pixels within each matrix or
`
`region within the frame. See Id. Col. 7 lines 28-29. The pixel location may
`
`be randomly assigned or may be set to a predetermined location.
`
`
`
`8
`
`
`
` Fig. 6 (shown above) shows a flowchart for determining “matrix or
`
`region” size based on pixel variation, which is the comparison of adjacent
`
`pixel data. Id. at col. 8 lines 24-26. Pixel variation is determined in block
`
`602 by comparing the adjacent pixels to determine a difference between the
`
`pixels. Id. at col. 8 lines 26-30. The variation between the pixels is then
`
`compared to threshold in block 604 and if the variation is greater than the
`
`threshold, a matrix size is assigned 606. Id. at col. 8 lines 33-37. If the
`
`variation is less than the threshold, the methodology goes to the next pixel in
`
`step 608, wherein each additional pixel that is below the threshold is added
`
`to the region. Id. at col. 8 line 41-48. Thus, the size and shape of the matrix
`
`is dependent on the comparison between adjacent pixels and the
`
`matrix/region can be any arbitrary shape that corresponds to the data
`
`variation from a region as small as or as large as warranted by the data in the
`
`frame. Additionally, the region can take on a completely arbitrary shape
`
`
`
`9
`
`
`
`based solely upon the pixel data that is presented and the setting of the
`
`threshold. The threshold can then be modified in 610. In embodiments of the
`
`invention as disclosed at col. 8 lines 49-52, the tolerance is modified with
`
`each increasing region size, such that smaller tolerances are imposed for
`
`larger regions. In other embodiments, a maximum region size can be
`
`imposed where the tolerance is set to zero.
`
`
`
`Fig. 10 graphically shows one embodiment of the segmentation of a
`
`frame into a plurality of regions. The segmentation shows that each region
`
`may be of a different size. The “x” within each region is the selected pixel
`
`that is selected by the pixel selection system that is transmitted with the
`
`matrix or other region data (e.g. the size, shape and location of the region
`
`
`
`10
`
`
`
`within the frame), so that the receiver can reconstruct the frame using the
`
`matrix data and the pixel data.
`
`
`
`III. CLAIM CONSTRUCTION
`In an inter partes review, the Patent Trial and Appeal Board gives
`
`patent claims their “broadest reasonable interpretation in light of the
`
`specification of the patent.” 37 C.F.R. § 42.100(b); Phillips v. AWH Corp.,
`
`415 F.3d 1303, 1316 (Fed. Cir. 2005) (en banc). Although, in an inter
`
`partes review, the Board embraces giving claims their “broadest reasonable
`
`interpretation”, this standard does not grant the Board unrestricted latitude
`
`for claim construction. In re Suitco Surface, Inc., 603 F.3d 1255, 1260 (Fed.
`
`Cir. 2010) (“The broadest construction rubric coupled with the term
`
`"comprising" does not give the PTO an unfettered license to interpret claims
`
`to embrace anything remotely related to the claimed invention….[rather,]
`
`claims should always be read in light of the specification and teachings in
`
`the underlying patent.”). The Board's construction “cannot be divorced from
`
`the specification and the record evidence,” and the claims must be
`
`“consistent with the one that those skilled in the art would reach.” Microsoft
`
`Corp. v. Proxyconn, Inc., 789 F.3d 1292, 1297-1298 (Fed. Cir. 2015), citing
`
`
`
`11
`
`
`
`In re NTP, Inc., 654 F.3d 1279, 1288 (Fed. Cir. 2011) and In re Cortright,
`
`165 F.3d 1353, 1358 (Fed. Cir. 1999).
`
`Patent Owner Vedanti presents the construction of certain claim terms
`
`below pursuant to the broadest reasonable interpretation consistent with the
`
`specification standard. The presented claim constructions are offered for the
`
`sole purpose of this proceeding and thus do not necessarily reflect
`
`appropriate claim constructions to be used in litigation and other
`
`proceedings wherein a different claim construction standard applies. To
`
`simplify and focus the review of this matter, claim constructions are
`
`provided where they will be helpful to the Board’s decision whether to
`
`institute an inter partes review on the instant petition. Claim constructions
`
`for other terms will be found in Patent Owner’s Preliminary Response filed
`
`simultaneously herewith in co-pending IPR2016-00215.
`
`“Frame Data”
`
`A.
`The term “frame data” should be construed by one of ordinary skill in
`
`the art using the broadest reasonable interpretation in view of the
`
`specification as “data assembled into a frame.” As used in the specification,
`
`“[s]ystem 400 thus allows optimized data, such as video data, audio data, or
`
`other suitable data, to be used to generate a display, an audio stream, graphic
`
`images, textual data, and other suitable data on a frame by frame basis.”
`
`
`
`12
`
`
`
`Thus, in isolation, the term “frame data” encompasses other types of data
`
`and is not limited to pixel data forming a still image. Frame data can include
`
`any of the data from a frame such as video, image, text or audio data.
`
`Contrary to Petitioner’s argument, the claims do not recite the term “image”
`
`or “video.” In the context of the ‘339 patent, given the variety of applicable
`
`data, the term “pixel data” refers to a sample point of any such data. As
`
`such, frame data is understood to refer to “data assembled into a frame.”
`
`“Region and Matrix”
`
`B.
`The term “region” should be construed using the broadest reasonable
`
`interpretation in view of the specification to mean “a contiguous group of
`
`pixels within a frame”. A region is created within the frame analysis system
`
`based upon a comparison of pixel data, such as adjacent pixel data to a
`
`threshold in order to determine if a pixel location should be included within
`
`a region. Exhibit 1001, col. 8 lines 26-44. Thus, a region is the result of an
`
`analysis of pixels to determine if they share common information and should
`
`be part of the same region.
`
`The term “matrix” is provided as an example of a “region” throughout
`
`the specification. Col. 4 lines 3-10 of the ‘339 patent describes exemplary
`
`matrices such as 1x1, 5x5 and non-symmetrical NxM matrices. Further that
`
`“other suitable data optimization regions can be selected, such as ones that
`
`
`
`13
`
`
`
`are not based on a matrix structure, but which may be circular, elliptical,
`
`amorphous, or based on other suitable structures.” Thus, in an image,
`
`regions can be any shape, whereas matrices are arrays of data points and a
`
`matrix is simply an example of a region.
`
` Col. 5 lines 60-64 of the ‘339 patent states:
`
`The pixel variation system 202 can generate
`nonsymmetrical matrix dimension data such as NxM
`dimensions where “N” and “M” are integers that are not
`equivalent, circular region data, elliptical region data,
`amorphous region data, or other suitable region
`identification data.
`
`
`Even the description of the figures such as Fig. 6 described at col. 2
`
`lines 18-20 uses the terms region and matrix in combination stating, “Fig. 6
`
`is a flowchart of a method for determining or assigning matrix or region
`
`size….” (emphasis added).
`
`C.
`
`“Region Data/Matrix Data/Matrix Definition
`Data/Optimized Matrix Data”
`
`Since the terms “region data” and “matrix data” are used in the same
`
`way, they are construed together. The terms “region data” and “matrix data”
`
`are construed together using the broadest reasonable interpretation in view
`
`of the specification to mean “data that defines the region including the size,
`
`
`
`14
`
`
`
`shape, and location of the region within a frame.” Col. 9 lines 7-12 states
`
`that “matrix or other region data is received. In one exemplary embodiment,
`
`the matrix data can include a matrix size, a region size, a region boundary
`
`for amorphous regions, or other suitable data.” The summary of the
`
`invention at Col. 1 lines 44-45 states that the generation of region data may
`
`include size information “such as a uniform matrix size.” Col. 5 lines 62-63
`
`uses the term region data in a similar context referring to circular region
`
`data, elliptical region data, and amorphous region data all of which are
`
`characterizations as to a shape. Col. 9 lines 52-53 states that “region data
`
`defines one or more regions within a frame”. The boundary of a region can
`
`be characterized by size, shape and location. Thus, region data may identify
`
`the size of the region, the shape of the region and the location of the region
`
`within a frame. As stated above, a matrix is an exemplary region and
`
`therefore the definition can be equally applied to the term “matrix data”
`
`wherein the region is a matrix.
`
`Similarly, the term “matrix definition data” finds support with respect
`
`to Fig. 4 and specifically with respect to matrix definition system 402 that is
`
`used for generating frame data. Col. 7 lines 18-27 describes the matrix
`
`definition data. In an exemplary embodiment, it is “data that identifies
`
`matrix dimensions and sequences” so that the matrices can be assembled
`
`
`
`15
`
`
`
`into a frame. Exhibit 1001, col. 7 line 23. The specification goes on more
`
`expansively “[l]ikewise, matrix definition system 402 can include region
`
`definition data, such as for ellipses, circles, amorphous shapes, or other
`
`suitable definition data”. Id., col. 7 lines 25-27. Thus, the “matrix definition
`
`data” generated by the matrix definition system should be construed under
`
`the broadest reasonable interpretation in view of the specification to mean
`
`“data that defines the region such as the size, shape, and location.”
`
`The term “optimized matrix data” should be construed by one of
`
`ordinary skill in the art in view of the specification to mean “matrix data
`
`which is optimized based upon the pixel variation data for the end use at the
`
`receiver”. Based on the specification as a whole, the system is optimized for
`
`the purpose of the receiver. The specification states that “in operation,
`
`system 100 allows data transmission to be optimized so as to decrease
`
`bandwidth requirements. System 100 determines the optimal data for
`
`transmission based on the end use of the data.” Id., Col. 4, lines 54-57.
`
`Elsewhere, the specification states, “Data transmission system 102 reduces
`
`data transmission requirements by eliminating data that is not required for
`
`the application of the data on the receiving end.” Id., Col. 3, lines 13-15.
`
`Petitioner only construes the terms “matrix definition data” and
`
`“matrix data” to mean “uniform matrix dimensions or non-uniform matrix
`
`
`
`16
`
`
`
`dimension and sequences.” It is more in keeping with the specification to
`
`recognize that this data conveys the size, shape and location of the regions,
`
`which include matrices. As mentioned above, Col. 9 lines 7-12 of the
`
`specification states that “the matrix data can include a matrix size, a region
`
`size, a region boundary for amorphous regions, or other suitable data.”
`
`Petitioner’s attempt to narrow the definition is contrary to the specification
`
`and contrary to the broadest reasonable interpretation.
`
`The parties agree “matrix definition data” and “matrix data” are terms
`
`particular to the specification given their meaning by the specification. The
`
`inventors have been their own lexicographers in their attempt to explain their
`
`invention. The inventors have specifically made clear in the specification
`
`that matrix definition data includes data that defines a region, such as the
`
`size, shape and location of the region within the frame, so that a frame can
`
`be reconstructed on the receiving side using the region data and
`
`corresponding pixel data for all of the regions. The construction proposed by
`
`Petitioner is overly narrow and fails to be the broadest reasonable
`
`construction in view of the specification.
`
` “Matrix Size Data”
`
`D.
`The broadest reasonable construction of “matrix size data” in view of
`
`the specification is “matrix data directed to matrix or region size”. The
`
`
`
`17
`
`
`
`matrix size system is described expansively as “matrix size system 204 can
`
`receive pixel variation data from pixel variation system 202, and can
`
`generate nonsymmetrical matrix dimensional data, …, circular region data,
`
`elliptical region data, amorphous region data, or other suitable region
`
`identification data.” Thus, the matrix size data generated by the matrix size
`
`system encompasses matrix or region size.
`
`“Pixel Variation Data”
`
`E.
`The term “pixel variation data” should be construed using the broadest
`
`reasonable interpretation in view of the specification to mean “the
`
`comparison of two pixels to determine the amount of variation between the
`
`two pixels”. This construction finds support at col. 5 lines 21-32. This
`
`passage from the specification describes the pixel variation system that “can
`
`compare two adjacent pixels to determine whether the amount of variation
`
`between those two adjacent pixels exceeds a predetermined tolerance.”
`
`“Pixel Selection Data”/“Selection Pixel Data”
`
`F.
`The terms pixel selection data and selection pixel data should be
`
`construed using the broadest reasonable interpretation in view of the
`
`specification to mean: “pixel data representative of a region of a frame for
`
`transmission to a receiver.” As stated in claim 7, “the selection pixel data
`
`and the optimized matrix data” are transmitted for assembly into a display
`
`
`
`18
`
`
`
`frame. Further, support for this interpretation can be found with relationship
`
`to Fig. 1 and specifically element 108, the pixel selection system. The pixel
`
`selection system “selects one or more pixels within a predefined matrix or
`
`other region for transmission in an optimized data system.” Exhibit 1001,
`
`Col. 4 lines 12-14.
`
`Petitioner attempts to suggest that the selected pixel data is
`
`transmitted without further processing for each region in a frame. Although
`
`the specification and prosecution history identify the methodology as not
`
`requiring compression (e.g. Id.,col. 2 line 41-46 etc.) , the specification
`
`clearly states at col. 5 lines 3-8 that “System 100 can also be used in
`
`conjunction with a compression system, a frame elimination system, or with
`
`other suitable systems or processes to achieve further savings in bandwidth
`
`requirements. For example, after data optimization has been achieved, the
`
`optimized data can then be compressed using a lossy or lossless compression
`
`technique.” Thus, Petitioner’s claim construction falters for being
`
`inconsistent with the specification. Moreover, the negative limitation
`
`“without processing” is undefined and it is unclear as to what does or does
`
`not constitute processing under Petitioner’s proposed claim construction. For
`
`these reasons, the Board should accept the definition of pixel selection data
`
`
`
`19
`
`
`
`or selection pixel data as “pixel data representative of a region of a frame for
`
`transmission to a receiver.”
`
`
`IV. OVERVIEW OF THE PRIOR ART
`A. Overview of Spriggs
`
`Spriggs discloses an image coding and transmission system. The
`
`coding method of Spriggs begins as shown in FIG. 4 and described at col. 2,
`
`line 27-35 by considering the original frame from its four corners ABCD.
`
`The process analyzes the frame and every block thereafter by pulling 4
`
`corner addresses off a stack, generating interpolated samples and comparing
`
`with actual samples. The result of this analysis either sets the frame as one
`
`large region defined by its corner samples or the frame is subdivided into
`
`four quadrants. The coding for performing the subdividing is shown in FIG.
`
`4. Exhibit 1005, col. 3 lines 51-55. The coding produces the coded output of
`
`FIG. 6. Id., col. 3 lines 63-65. The output in FIG. 6 defines the regions by
`
`indicating the corner values SA, SB, SC… and by including division codes,
`
`wherein a subdivided block is indicated by a “1” and wherein a “0” indicates
`
`a region that is not subdivided. Id., col. 3 lines 2-9.
`
`According to the Petition the coded output defining the corner
`
`coordinates and values corresponds to the region data. The region data of
`
`Spriggs determined by the processor 14 in FIG. 5 is transmitted through
`
`
`
`20
`
`
`
`output port 16. There is no pixel selection system to receive that region data
`
`and generate a set of selected pixel data. Rather, Spriggs teaches that by
`
`exploiting the highly recursive process it reduces the address data to
`
`approximately one bit per corner point. Thus, the purpose of Spriggs in
`
`reducing addressing overhead depends on subdividing a frame only into
`
`rectangular regions that can be defined by corner points.
`
`B. Overview of Golin
`Golin discloses a video compression system. Each region of a video
`
`frame is custom encoded. Exhibit 1006, col. 4, line 68-col. 5, line 1. Golin
`
`teaches a roughness estimator for detecting edges in the pixel data and if
`
`such edges or “roughness” make the encoding process unacceptable, the
`
`region is split horizontally or vertically. Petitioner relies on Golin for its
`
`disclosure of a roughness estimator, it is not relied upon to show pixel
`
`selection. The asserted combination incorporates the roughness test into
`
`Spriggs to perform block subdivision decisions.
`
`
`
`
`
`
`
`
`
`21
`
`
`
`V.
`
`
`SINCE THE PRIOR ART DOES NOT RENDER ANY CLAIM
`OBVIOUS, NO INTER PARTES REVIEW SHOULD BE
`INITIATED
`A. Because Petitioner conflates the terms “region data” and
`“pixel data,” the Petitioner has failed to show that the prior
`art teaches “a pixel selection system” that receives “region
`data” and generates “pixel data” for each region according
`to claim 1 and therefore, Petitioner has failed to establish a
`prima facie case of obviousness for claims 1, 6, and 13.
`
`Contrary to the assertion by the Petitioner, the prior art at most
`
`teaches the generation of “region data” and does not include a subsequent
`
`step for generating “pixel data” for each region in a “pixel selection system”
`
`as required by claim 1. The Petitioner conflates the term “region data” with
`
`the term “pixel data” to attempt to show both when only one is present. An
`
`algorithm corresponding to a “pixel selection system” receiving region data
`
`to generate pixel data is entirely lacking.
`
`Claim 1 requires:
`
`a) an analysis system …..generating region data; and
`
`b) a pixel selection system receiving the region data and generating
`
`one set of pixel data for each region forming a new set of data for
`
`transmission…...(emphasis added)
`
`In the petition at pages 30-31, the Petitioner suggests that the required
`
`“pixel selection system” of claim 1 is taught by the patent of Spriggs (US.
`
`
`
`22
`
`
`
`4,791,486 Exhibit 1005) and does not suggest that the secondary reference
`
`of Golin (U.S. 5,225,904 Exhibit 1006) teaches or suggests such a pixel
`
`selection system.1 Thus, Patent Owner now only addresses the reference of
`
`Spriggs with respect to the required “pixel selection system.”
`
`According to Petitioner, Spriggs teaches a frame analysis system that
`
`generates region data for a division of a frame. Petition, Paper 2 at 26. Such
`
`system of Spriggs “executes the instructions to “perform the coding.”” Id. at.
`
`27. The Petition refers to Spriggs, col. 3, lines 53-54, which identifies the
`
`coding at FIG. 4. The coding produces the coded output of FIG. 6. Exhibit
`
`1005, Col. 3 lines 63-65. The frame analysis begins as shown in FIG. 4 and
`
`as recited in the petition by generating the four corners ABCD. Next in FIG.
`
`4, the corner samples are transmitted SA, SB, SC, SD.
`
`As indicated in the Petition at p. 27, “If the block cannot be
`
`reconstructed from only the four corner values, the block is subdivided as in
`
`FIG.2 into smaller blocks…” This recursive process is described at col. 2,
`
`lines 51-54 and is illustrated, through the frame analysis method of FIG. 4.
`
`The process analyzes the block by pulling 4 corner addresses off stack,
`
`1 The Petitioner relies on Golin solely for the teaching of “ a number of
`
`strategies [] for deciding when a sub-region should be split…” such as, pixel
`
`variation edge detection. Petition, Paper 2 at 23-24.
`
`
`
`23
`
`
`
`generating interpolated samples and comparing with actual samples. If the
`
`actual samples compared with the interpolated samples exceed a threshold
`
`(are not within margin), corner addresses of subareas are generated and
`
`pushed onto the stack. In Fig. 2, the new points are RPSTQ. In Fig. 6, the
`
`new points are represented by EFGHI. A “1” is transmitted to indicate that a
`
`subdivision has been made and the additional corner samples are
`
`transmitted. This data is shown in the second row of FIG. 6 as 1 SE SF SG
`
`SH SI.
`
`The Petition summarizes the frame analysis system as follows: “the
`
`recursive region forming process produces region data (the blocks as defined
`
`by the corner coordinates and values) comprised of high
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
