UNITED STATES PATENT AND TRADEMARK OFFICE
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`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`GOOGLE INC.,
`Petitioner
`
`v.
`
`VEDANTI SYSTEMS LIMITED,
`Patent Owner
`
`___________________
`
`Case IPR2016-002121
`Patent 7,974,339 B2
`___________________
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`PETITIONER’S REPLY
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`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`1 Case IPR2016-00215 has been consolidated with this proceeding.
`
`
`
`
`
`

`
`
`
`IV.
`
`B.
`
`C.
`
`D.
`
`TABLE OF CONTENTS
`I.
`Introduction ...................................................................................................... 1
`Person Of Ordinary Skill In The Art ............................................................... 2
`II.
`III. Claim Construction .......................................................................................... 4
`A.
`“Frame Data” ......................................................................................... 4
`B.
`“Region” and “Matrix” .......................................................................... 4
`C.
`“Region Data/Matrix Data/Matrix Definition Data” and “Data” ......... 5
`D.
`“Matrix Size Data” ................................................................................ 6
`E.
`“A[n] Analysis System Receiving Frame Data And Generating
`Region Data” ......................................................................................... 8
`“Pixel Selection Data/Selection Pixel Data” ......................................... 9
`F.
`“Selecting One Of Two Or More Sets Of Pixel Data” .......................10
`G.
`“Selecting A Set Of Pixel Data From Each Region” ..........................12
`H.
`IPR2016-00212 ..............................................................................................13
`A.
`The claimed “inventions” of the ’339 patent are rendered obvious by
`Spriggs in view of Golin. ....................................................................13
`Spriggs in view of Golin discloses “analysis” and “pixel selection”
`systems as recited in claims 1, 6, and 13.............................................14
`Spriggs in view of Golin discloses separate and distinct “region data”
`and “pixel data.” ..................................................................................17
`Spriggs in view of Golin discloses a “pixel selection system receiving
`the region data and generating one set of pixel data for each region” as
`recited in claims 1, 6, and 13. ..............................................................18
`Spriggs in view of Golin discloses “selecting one of two or more sets
`of pixel data based on the optimized matrix data” as recited in claims
`7 and 9. ................................................................................................20
`Spriggs in view of Golin discloses “selecting a set of pixel data for
`each region” as recited in Claims 10 and 12. ......................................21
`IPR2016-00215 ..............................................................................................23
`A.
`Belfor’s approach of dividing a frame into uniform sized blocks can
`be substituted with Thyagarajan’s subdivision approach, which
`generates non-uniform sized blocks. ...................................................23
`
`E.
`
`F.
`
`V.
`
`
`
`
`
`

`
`
`
`B.
`
`C.
`
`Incorporating the non-uniform block sizes of Thyagarajan with
`Belfor’s encoding and decoding process was well within the ability of
`a POSA. ...............................................................................................26
`Belfor in view of Thyagarajan and further in view of Golin discloses
`the “region data,” the “data receiving system receiving the region data
`… and generating a display,” and the “display generation system
`receiving pixel location data” as recited in claim 1. ...........................29
`Belfor in view of Thyagarajan and further in view of Golin discloses
`the “assembling” steps of claims 7 and 10. .........................................30
`Dr. Grindon’s visualizations of regions in Belfor was provided simply
`to demonstrate that even multiple contiguous uniform blocks in Belfor
`can logically constitute non-uniform regions. .....................................31
`The Petition did not foster any misconceptions about the cited
`references. ............................................................................................32
`VI. Conclusion .....................................................................................................34
`
`
`D.
`
`E.
`
`F.
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`- ii -
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`
`I.
`
`Introduction
`
`U.S. Patent Number 7,974,339 (’339 patent) discloses a basic approach to
`
`reducing the amount of data transmitted for an image. The process described in the
`
`’339 patent divides an image into multiple regions. For each region, rather than
`
`transmitting all the pixels, the process transmits at least one pixel to represent the
`
`entire region. As demonstrated in Google’s two Petitions, the ’339 patent’s
`
`approach was well known and not patentable.
`
`In the Patent Owner Response (POR), Vedanti asserts one line of attack
`
`against the Spriggs-based grounds, and another line of attack against the Belfor-
`
`based grounds. Specifically, all of Vedanti’s challenges to the Spriggs-based
`
`grounds contend that the Spriggs-Golin combination fails to include an “analysis
`
`system” and a “pixel selection system.” All of Vedanti’s challenges to the Belfor-
`
`based grounds contend that a POSA could not have combined Belfor and
`
`Thyagarajan.
`
`As detailed below, Vedanti is wrong. As identified in the IPR2016-00212
`
`Petition, the transmitter in the Spriggs-Golin combination includes both an
`
`“analysis system” and a “pixel selection system.” (IPR2016-00212 Petition, 26-
`
`31). As further explained in the IPR2016-00215 Petition, a POSA would have
`
`combined Belfor with Thyagarajan to arrive at the claims of the ’339 patent.
`
`(IPR2016-00215 Petition, 22-26.)
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`Google therefore requests that the Board cancel claims 1, 6, 7, 9, 10, 12, and
`
`13 of the ’339 patent as unpatentable in both the IPR2016-00212 and IPR2016-
`
`00215 proceedings.
`
`II.
`
`Person Of Ordinary Skill In The Art
`
`Google
`B.S. degree in Electrical
`Engineering, Computer Engineering,
`Computer Science, or an equivalent
`field, as well as at least one year of
`academic or industry experience in
`image processing or data
`transmission
`
`Vedanti
`a technical degree in Electrical
`Engineering, Computer Science or
`equivalent curriculum with
`coursework in image processing and
`at least one year of hands on
`experience with compression and
`communication techniques
`
`Or
`
`degree in Electrical Engineering,
`Computer Science or equivalent
`curriculum with coursework in
`compression and communication
`and at least one year of hands on
`experience in image compression
`
`
`
`Attempting to disqualify Google’s expert Dr. Grindon, Vedanti proposes a
`
`standard for a person of ordinary skill in the art (POSA) that is directly at odds
`
`with the ’339 patent. Vedanti’s proposed standard requires a POSA to have either
`
`coursework in compression or one year of hands-on experience with compression.
`
`But the ’339 patent is explicit that its alleged inventions involve “data transmission
`
`[] that use[s] data optimization instead2 of compression.” (GOOG 1001, 1:32-39;
`
`2 Emphasis added unless otherwise indicated.
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`see also 1:53-63, 2:41-46.) The ’339 patent states that any use of compression with
`
`its alleged inventions is optional, and nowhere do the claims recite compression.
`
`(GOOG 1001, 5:3-11.)
`
`Even Vedanti’s expert Dr. Kia conceded that knowledge of compression is
`
`not required to practice the ’339 patent. When questioned about the patent’s
`
`statement
`
`that
`
`the alleged
`
`inventions use “data optimization
`
`instead of
`
`compression” (GOOG 1001, 1:32-39), Dr. Kia testified that the compression
`
`referenced in the ’339 patent is entropy coding and that no knowledge of entropy
`
`coding is required to practice the data optimization of the ’339 patent. (GOOG
`
`1034, 57:14-59:1, 63:22-64:16.)
`
`Given that the ’339 patent explicitly distinguishes its alleged inventions
`
`from compression, and that no knowledge of compression is required to practice
`
`the’339 patent’s teachings, there is no basis for requiring a POSA to have
`
`coursework or one year of hands-on experience with compression.
`
`Vedanti’s proposed POSA standard should thus be rejected. Nevertheless,
`
`Google’s expert Dr. Grindon satisfies Vedanti’s POSA standard. Dr. Grindon’s
`
`experience includes formal undergraduate and graduate coursework and/or
`
`practical experience over many years, working as an engineer and on patent
`
`litigations in technologies including signal and image compression, image
`
`processing, transform methods, sampled data systems, communications theory,
`
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`information theory, and statistical processes. (GOOG 1030, ¶ 16.)
`
`Given Vedanti’s proposal for a different POSA standard, Dr. Grindon
`
`reviewed his declarations (GOOG 1003; GOOG 1029) submitted with the Petitions
`
`in this consolidated proceeding, and has determined that all of his statements
`
`remain valid and applicable even under Vedanti’s POSA standard.3
`
`III. Claim Construction
`“Frame Data”
`A.
`Google and Vedanti previously proposed different constructions for “frame
`
`data,” but the Board chose not to construe “frame data” in its Institution Decisions.
`
`Google agrees that no construction of “frame data” is necessary to address the
`
`instituted grounds, given
`
`that (1) Vedanti does not challenge Google’s
`
`identification of “frame data” in any of the instituted Grounds and (2) raises no
`
`dispute that would be resolved by a construction of “frame data.”
`
`To the extent that construction is necessary, Google maintains that the
`
`broadest reasonable interpretation (BRI) of “frame data” is “image comprised of
`
`pixel data,” as stated in its Petitions.
`
`“Region” and “Matrix”
`
`B.
`In the POR, Vedanti does not dispute the Board’s BRI constructions of
`
`3 Hereinafter, a reference to a POSA refers to a person who qualifies under both
`
`parties’ proposed POSA standards.
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`“region” and “matrix,” which are the same as the constructions proposed by
`
`Google in its Petitions. The parties therefore do not dispute the Board’s BRI
`
`constructions of “region” and “matrix.”
`
`“Region Data/Matrix Data/Matrix Definition Data” and “Data”
`
`C.
`The Board construed the BRI of “region data” as “data that defines at least
`
`one region.” The Board also construed the BRIs of “matrix data” and “matrix
`
`definition data” as “data that defines at least one matrix,” which are broader than
`
`the constructions Google proposed in its Petitions. As the Board’s BRI
`
`constructions of “region data,” “matrix data,” and “matrix definition data” are
`
`broader than Google’s proposals, Google submits that its arguments and analysis
`
`presented in the petition are unchanged and remain applicable under the Board’s
`
`BRI constructions.
`
`Although Vedanti had no difficulty understanding the term “data” in its
`
`POPRs, Vedanti now contends that “data” needs to be construed as “digital
`
`information or bits that can be made available for storage, transmission and/or
`
`interpretation.” The term “data,” however, is used in an ordinary manner in the
`
`claims and in the specification and therefore requires no construction. (GOOG
`
`1030, ¶ 23.)
`
`If the Board deems construction necessary, the BRI of “data” is “information
`
`in a form suitable for storing and processing by a computer.” The ’339 patent does
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`not explicitly define the term “data,” but uses the term to refer to information used
`
`by computing systems. (GOOG 1001, 2:41-49, 2:65-3:12; GOOG 1030, ¶ 26.)
`
`Consistent with the ’339 patent’s use of that term, dictionaries published near the
`
`patent’s earliest possible priority date (January 2002) defined “data” as follows:
`
`• “information in a form suitable for storing and processing by a computer”
`(GOOG 1032 (Webster’s New World College Dictionary, Fourth Edition,
`1999), 368.)
`
`• “Factual information (such as text, numbers, sounds, and images) in a
`form that can be processed by a computer” (GOOG 1031 (Webster’s
`New World Dictionary of Computer Terms, 7th Edition, 1999), 137.)
`
`• “Plural of the Latin datum, meaning item of information. In practice, data
`is often used for the singular as well as the plural form of the noun”
`(GOOG 1033 (Microsoft Computer Dictionary, Fourth Edition), 1999),
`122.)
`
`Consistent with the ’339 patent and contemporaneous dictionary definitions, a
`
`POSA would have understood the BRI of “data” to be “information in a form
`
`suitable for storing and processing by a computer.” (GOOG 1030, ¶¶ 23-28.)
`
`“Matrix Size Data”
`
`D.
`No construction of “matrix size data” is necessary given that Vedanti does
`
`not raise a challenge to any instituted ground that is dependent on a construction of
`
`that term.
`
`If the Board still deems construction necessary, Vedanti’s proposed
`
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`construction of “matrix size data” as “matrix data directed to matrix or region size”
`
`should be rejected. The ’339 patent distinguishes matrix type regions from other
`
`circular, elliptical, and amorphous type regions. (GOOG 1001, 4:6-11.) A POSA
`
`would therefore have recognized that “matrix size data” is directed only towards
`
`matrix type regions and not to any other types of regions as Vedanti proposes.
`
`(GOOG 1030, ¶ 30.)
`
`The BRI of “matrix size data” is “data that defines a dimension of a matrix.”
`
`(GOOG 1030, ¶¶ 31-37.) Although the ’339 patent does not provide an explicit
`
`definition of “matrix size data,” it uses the phrase “matrix size” to refer to a
`
`dimension of a matrix. For example, the ’339 patent states, “the matrix size … can
`
`be uniform, such that each … matrix has the same dimensions” and “matrix size
`
`system 204 … can generate nonsymmetrical matrix dimensional data, such as
`
`N×M dimensions where ‘N’ and ‘M’ are integers that are not equivalent.” (GOOG
`
`1001, 3:57-59, 5:58-62.)
`
`A POSA would have known that such N×M dimensions of a matrix can be
`
`provided in both explicit and implicit forms. (GOOG 1030, ¶ 33.) For example,
`
`such N×M dimensions can be provided explicitly as N and M values. (Id.)
`
`Alternatively, corner coordinates of a matrix, division codes of Spriggs, PQR
`
`values of Thyagarajan, and other similar types of data allow N and M values to be
`
`ascertained implicitly. (Id., ¶¶ 34-36.) Vedanti’s expert Dr. Kia acknowledged
`
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`during his deposition that, when the universe of matrix sizes are limited to a
`
`specific set, the size of a matrix can be provided implicitly in an encoded format so
`
`that fewer bits are needed to transmit the matrix size than the actual N and M
`
`values. (GOOG 1034, 43:19-45:13.)
`
`A POSA would therefore have understood the BRI of “matrix size data” to
`
`be “data that defines a dimension of a matrix” either explicitly or implicitly.
`
`E.
`
`“A[n] Analysis System Receiving Frame Data And Generating
`Region Data”
`
`As the Board indicated in its Institution Decisions, no construction is needed
`
`for the phrase “a[n] analysis system receiving frame data and generating region
`
`data.”
`
`Vedanti’s proposed construction should be rejected because it does nothing
`
`to clarify the phrase, and instead attempts to import an exemplary embodiment of
`
`the specification into the claims by requiring the “analysis system” to be
`
`“separately identifiable from the pixel selection system.” (POR, 18-22.) The
`
`specification is clear that its separate depiction of an “analysis system” and “pixel
`
`selection system” is exemplary. (GOOG 1001, 2:3-5, 2:41-43, 2:65-66). The
`
`specification also states that its exemplary embodiments may be modified without
`
`departing from the scope of the claims. (GOOG 1001, 10:55-60.) The ’339 patent
`
`thus leaves open the possibility that the claims can cover a single system that
`
`functions and qualifies as both the claimed “analysis system” and the “pixel
`
`
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`selection system.” See Cannon Rubber Ltd. v. The First Years, Inc., 163 F. App'x
`
`870, 876 (Fed. Cir. 2005) (“We see no reason why a single structural element ...
`
`which performs two separate functions, cannot support a claim reciting broadly
`
`these two separate functions.” (citing In re Kelley, 49 C.C.P.A. 1359, 305 F.2d
`
`909, 914 (1962)).) There is no basis in the ’339 patent for limiting the BRI of
`
`“analysis system” to require the claimed “analysis system” to be always embodied
`
`separately from the claimed “pixel selection system.”4
`
`“Pixel Selection Data/Selection Pixel Data”
`
`F.
`As Google explained in its Petitions, the BRIs of “pixel selection data” and
`
`“selection pixel data” should exclude any pixel data that is transmitted while
`
`needing further processing. In rejecting Google’s view, the Board incorrectly
`
`focused on a passage in the specification stating that the ’339 patent’s data
`
`optimization approach can be used “in conjunction with a compression system, a
`
`frame elimination system, or with other suitable systems or processes.” (Paper 7,
`
`10-12; Paper 8, 10-11; GOOG 1001, 5:3-8) That passage describes an embodiment
`
`that was specifically disclaimed during the prosecution of the ’339 patent in order
`
`to obtain allowance. The’339 patent Applicants argued during prosecution that the
`
`4 As detailed in section IV.B below, the Spriggs-based grounds nonetheless include
`
`separately identifiable “analysis” and “pixel selection” systems, contrary to
`
`Vedanti’s contentions.
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`claimed “pixel data is selected directly … and will be transmitted without any
`
`further processing, due to the fact that the applicants[’] invention does not
`
`compress nor decompress data.” (GOOG 1002, pp. 556-595; IPR2016-00212
`
`Petition, 18-19; IPR2016-00215 Petition, 17-18.) Google maintains that the BRI of
`
`both “pixel selection data” and “selection pixel data” is “selected pixel data
`
`transmitted without any further processing for each region in a frame.”
`
`Nevertheless, the instituted grounds render the challenged claims obvious
`
`under the Board’s constructions, which are broader than Google’s constructions
`
`proposed in its Petitions. Thus the instituted grounds can be evaluated without
`
`resolving whether the BRIs of “pixel selection data” and “selection pixel data”
`
`need to exclude pixel data that is transmitted while needing further processing.
`
`“Selecting One Of Two Or More Sets Of Pixel Data”
`G.
`For the phrase “selecting one of two or more sets of pixel data,” Vedanti’s
`
`construction merely replaces the phrase “selecting” with the phrase “requiring a
`
`decision to choose between.” Nothing in the ’339 patent warrants defining
`
`“selecting” in such a narrow fashion as to require a decision be made in addition to
`
`simply performing the act of choosing.
`
`The claims and the specification of the ’339 patent use the term “selecting”
`
`in an ordinary manner to mean “picking or choosing at least one item from
`
`multiple items.” (GOOG 1030, ¶¶ 39-41.) For example, claims 4 and 5 recite
`
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`“selecting one of the two or more sets of pixel data,” and claim 8 recites “selecting
`
`the pixel from a matrix of sets of pixel data.” The Abstract, for example, states, “A
`
`pixel selection system … generates one set of pixel data for each region, such as by
`
`selecting one of the pixels contained within each of the original matrices.” (GOOG
`
`1001, see also 1:46-49) Nothing in the claims or in the specification suggests that
`
`“selecting” means anything other than simply picking or choosing at least one item
`
`from multiple items.
`
`Consistent with the ’339 patent’s use of the term “selecting,” dictionaries
`
`published near the patent’s earliest possible priority date (January 2002) defined
`
`“selecting” as follows:
`
`• “to choose or pick out from among others” (GOOG 1032 (Webster’s
`New World College Dictionary, 4th Edition, 1999), 1299.)
`
`• “In information processing, to choose from a number of options or
`alternatives” (GOOG 1033 (Microsoft Computer Dictionary, 4th Edition),
`1999), 401.)
`
`Vedanti’s expert Dr. Kia also testified that “selecting” in the ’339 patent means
`
`“picking from a choice.” (GOOG 1034, 125:4-7.) Consistent with the patent’s
`
`usage of the term “selecting,” contemporaneous dictionary definitions, and the
`
`opinions of the experts in these proceedings, a POSA would have understood that
`
`“selecting” is used in an ordinary manner in the ’339 patent. Thus, no construction
`
`is needed for “selecting one of two or more sets of pixel data.”
`
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`Case IPR2016-00212 of
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`If the Board deems construction necessary, the BRI of “selecting one of two
`
`
`
`or more sets of pixel data” is “picking or choosing one of two or more sets of pixel
`
`data” to reflect the patent’s ordinary use of the term “selecting” in the ’339 patent.
`
`(GOOG 1030, ¶¶ 38-44.)
`
`“Selecting A Set Of Pixel Data From Each Region”
`
`H.
`The phrase “selecting a set of pixel data from each region” requires no
`
`construction because it can be understood as stated. As discussed above, the patent
`
`uses the term “selecting” in an ordinary manner to mean picking or choosing.
`
`(Supra III.G.) The parties do not contend that “pixel data” needs to be construed in
`
`order to be understood.5 The parties agree that for at least these proceedings,
`
`“region” means a “division of a frame.” (Supra III.B.) The remaining terms in the
`
`phrase “selecting a set of pixel data from each region” are common and ordinary
`
`words. Hence, the phrase “selecting a set of pixel data from each region” can be
`
`understood without further construction.
`
`Vedanti, however, attempts to narrow the phrase to require that a “process”
`
`be “performed.” (POR, 24.) Imputing that requirement would only cause confusion
`
`and raise further questions about what is meant by a “process” and what types of
`
`processes qualify under Vedanti’s proposed construction. (GOOG 1030, ¶ 46.) If
`
`5 For example, Vedanti’s proposed construction for the claim phrase “selecting one
`
`of two or more sets of pixel data” re-defines “selecting”, not “pixel data.”
`
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`Vedanti had desired to limit its claims to certain processes for selecting a pixel, it
`
`should have included such limitations explicitly in the claims during prosecution,
`
`rather than attempt to shoehorn in such a requirement now through claim
`
`construction.
`
`If the Board deems construction necessary, the BRI of “selecting a set of
`
`pixel data from each region” is “picking or choosing a set of pixel data from each
`
`region” to reflect the patent’s ordinary use of the term “selecting” as discussed
`
`above. (GOOG 1030, ¶¶ 45-48.)
`
`IV.
`
`IPR2016-00212
`A. The claimed “inventions” of the ’339 patent are rendered obvious
`by Spriggs in view of Golin.
`
`In its POR section VI.B.a, Vedanti alleges generally, without tying its
`
`allegations to any specific claim language, that the alleged inventions described in
`
`the ’339 patent are not found in the Spriggs-based grounds. (POR, 33-37.) But the
`
`inventions as claimed are what is relevant to the invalidity analysis—not other
`
`“inventions” described elsewhere in the patent. As provided in the IPR2016-00212
`
`Petition, when looking at the claim language, the Spriggs-based grounds are no
`
`different from the inventions claimed in the ’339 patent.
`
`The general allegations in Vedanti’s POR section VI.B.a nonetheless fall
`
`flat, failing even when restated in sections VI.B.b-f of its POR (37-54) against
`
`specific claim language. For example, as discussed below in section IV.B, the
`
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`Case IPR2016-00212 of
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`combination of Spriggs and Golin discloses the claimed “analysis system” and
`
`“pixel selection system.” As discussed in section IV.D, the combination of Spriggs
`
`and Golin discloses the claimed “pixel selection system” that “receive[s] region
`
`data” and “generate[s] one set of pixel data for each region.” (See also, infra IV.F)
`
`The same combination also discloses selecting claimed “pixel data” based on the
`
`clamed “optimized matrix data.” (Infra IV.E). As provided in the IPR2016-00212
`
`Petition, Spriggs in view of Golin renders obvious claims 1, 6, 7, 9, 10, 12, and 13
`
`of the ’339 patent.
`
`B.
`
`Spriggs in view of Golin discloses “analysis” and “pixel selection”
`systems as recited in claims 1, 6, and 13.
`
`The combination of Spriggs and Golin discloses an “analysis system” and a
`
`separate “pixel selection system,” despite Vedanti’s allegations to the contrary
`
`(POR, 37-41). As explained in the IPR2016-00212 Petition (at 26), Spriggs’
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`transmitter executes a coding process on an input frame. (GOOG 1005, 3:51-59.)
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`As detailed below, a POSA would have recognized that certain steps in that coding
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`process correspond to the claimed “analysis system,” while other separate steps
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`correspond to the claimed “pixel selection system.” (GOOG 1030, ¶¶ 49-55.)
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`In Spriggs, when the transmitter receives a frame, the transmitter performs
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`certain steps of the coding process to divide the frame into blocks. (Id., ¶ 50;
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`GOOG 1005, 2:26-3:24, 3:51-62.) Each time new blocks are created, the coding
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`process generates corner coordinates of each block and transmits a division code
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`‘1’ to a receiver to indicate the creation of the new blocks.6 (GOOG 1005, 2:26-
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`3:24, 3:51-62; GOOG 1030, ¶ 50) Such corner coordinates are “region data,”
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`because they define the size and location of a block within the frame. (GOOG
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`1030, ¶ 50.) The parties agree that division codes of Spriggs are also “region data.”
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`(POR, 47; IPR2016-00212 Petition, 30.)
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`Such “region data” are provided by Spriggs’ transmitter to a receiver both
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`directly and indirectly. (GOOG 1030, ¶ 51.) The division code values ‘1’ and ‘0’
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`are transmitted directly. (GOOG 1005, 3:3-5.) The corner coordinates of each
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`block are provided indirectly through division codes. (Id., 3:24-29.) A receiver
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`“can work out from the [division code] ‘0’s and ‘1’s … the addresses [i.e.,
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`coordinates] of sample points” at the corners of each block. (Id.; GOOG 1030, ¶
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`51.)
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`Accordingly, Spriggs discloses that certain steps in the transmitter’s coding
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`6 Vedanti contends that a block in Spriggs is not created until a division code ‘0’ is
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`transmitted. But Spriggs plainly contradicts this. Spriggs states, “If it is decided
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`that the block must be sub-divided, a ‘1’ is transmitted. The block is sub-divided
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`into four by cutting it in half horizontally and vertically.” (GOOG 1005, 3:4-7)
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`Accordingly, Spriggs discloses that new blocks are created through sub-division
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`upon the transmission of a division code ‘1.’
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`process perform the functions of the claimed “analysis system,” by receiving a
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`frame and generating “region data” (such as corner coordinates of each block or
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`division codes) that is provided to the receiver. (IPR2016-00212 Petition, 26-29;
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`GOOG 1030, ¶ 52.)
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`Spriggs further discloses that, when new blocks are created, its transmitter
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`performs additional steps in its coding process to select and transmit the values of
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`the pixels at the corners of the newly created blocks. (Id., ¶ 53; GOOG 1005, 3:30-
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`59, 3:63-68.) As noted in the Petition, such pixel values correspond to the claimed
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`“pixel data” of the ’339 patent. (IPR2016-00212 Petition, 30-31.) So that the
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`transmitter could select and transmit the appropriate “pixel data” for newly created
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`blocks, a POSA would have recognized that the additional steps of the coding
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`process would utilize the “region data” generated earlier in the coding process.
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`(GOOG 1030, ¶ 53.) Specifically, a POSA would have recognized that the
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`information indicating that new blocks have been created (e.g.¸ division code of
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`‘1’) would be used to trigger the additional steps for selecting and transmitting the
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`pixel values. (Id.) The corner coordinates of the newly created blocks would be
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`used to select the values of the pixels at those locations for transmission. (Id.;
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`GOOG 1005, 3:16-17.)
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`Accordingly, Spriggs discloses that the additional steps in the transmitter’s
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`coding process perform the functions of the claimed “pixel selection system,” by
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`receiving “region data” and generating “pixel data” for each new block that is
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`created. (IPR2016-00212 Petition, 30-31; GOOG 1030, ¶ 54.)
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`A POSA would thus have recognized that certain steps in the coding process
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`of the Spriggs transmitter correspond to the claimed “analysis system,” while other
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`steps in that process correspond to the claimed “pixel selection system.” (GOOG
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`1030, ¶¶ 49-55.)
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`C.
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`Spriggs in view of Golin discloses separate and distinct “region
`data” and “pixel data.”
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`Despite Vedanti’s miscomprehension (POR, 41-45), the IPR2016-00212
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`Petition identifies separate and distinct “pixel data” and “region data.” The Petition
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`identifies the “pixel values” of Spriggs as the claimed “pixel data.” (IPR2016-
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`00212 Petition, 30-31, 44, 51.) The Petition identifies “division codes (0, 1),”
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`“addresses of corner values” of pixels forming a block, and “blocks as defined by
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`corner coordinates and values” as the claimed “region data” and “matrix data.”
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`(IPR2016-00212 Petition, 27, 30, 39, 41, 43, 55.) Thus, while the claimed “pixel
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`data” in Spriggs is only the value of a pixel, the claimed “region data” or “matrix
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`data” can be division codes, addresses of corner values, or blocks defined by
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`corner coordinates and values. Hence, the claimed “pixel data” in Spriggs cannot
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`by itself be the claimed “region data,” and vice versa.
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`D.
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`Case IPR2016-00212 of
`Patent No. 7,974,339 B2
`Spriggs in view of Golin discloses a “pixel selection system
`receiving the region data and generating one set of pixel data for
`each region” as recited in claims 1, 6, and 13.
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`Vedanti contends that the IPR2016-00212 Petition fails to identify a “pixel
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`selection system” that receives “region data” and thereafter generates “one set of
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`pixel data for each region.” (POR, 45-50.) But as discussed above (supra IV.B), a
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`POSA would have recognized that certain steps in Sprigg’s coding process is
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`analogous to the claimed “pixel selection system.” Those steps receive “region
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`data” (corner coordinates of newly created blocks or division codes), and generate
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`“pixel data” (corner pixel values). (Supra IV.B.) Although no specific sequence is
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`required in the claims, those steps generate “pixel data” for a particular region after
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`the associated “region data” is received.
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`When “region data” is in the form of corner coordinates, Sprigg’s transmitter
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`generates “pixel data” after the corner coordinates are received. (GOOG 1030, ¶
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`59.) Given that the corner coordinates are a prerequisite for selecting the pixel
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`values at those coordinates, corner pixel values (i.e., “pixel data”) can only be
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`obtained after receiving the corner coordinates (i.e., “region data”). (Id.)
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`For “region data” in the form of division codes, Spriggs discloses that corner
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`pixel values (i.e., “pixel data”) may be transmitted after a division code ‘1’ is
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`transmitted (GOOG 1005, 3:44-50) or, as Vedanti’s expert Dr. Kia acknowledged,
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`after a division code ‘0’ is transmitted (Id., 3:36-38; GOOG 1034, 81:21-82:13).
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`Case IPR2016-00212 of
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`Thus, a POSA would have recognized that when the Spriggs transmitter, while
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`performing its coding process, receives informa