`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`TESLA, INC.,
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC.,
`Patent Owner
`
`———————
`
`IPR2025-00339
`U.S. Patent No. 7,916,180
`
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT 7,916,180
`
`i
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
`
`CERTIFICATION OF GROUNDS FOR STANDING .................................. 1
`
`III. NOTE ............................................................................................................... 1
`
`IV. THE ’180 PATENT ......................................................................................... 2
`
`A.
`
`B.
`
`C.
`
`Summary ............................................................................................... 2
`
`Prosecution History ............................................................................... 3
`
`Effective Filing Date ............................................................................. 4
`
`V.
`
`LEVEL OF ORDINARY SKILL IN THE ART ............................................. 6
`
`VI. CLAIM CONSTRUCTION ............................................................................ 6
`
`A.
`
`“simultaneous data acquisition with each of the first and second
`channels during a frame” (claim 22) .................................................... 6
`
`B.
`
`“data of a frame”(claim 1) .................................................................... 8
`
`VII. THE CHALLENGED CLAIMS ARE UNPATENTABLE ............................ 9
`
`A.
`
`B.
`
`C.
`
`Challenged Claims ................................................................................ 9
`
`Prior Art Patents and Printed Publications ............................................ 9
`
`Statutory Grounds for Challenges .......................................................10
`
`D. Ground 1: Claims 1-3, 10-12, 22, 24-25, 28, 30, and 32-33 would
`have been obvious over Matsushima and Yu. .....................................10
`
`1.
`
`2.
`
`Overview of Matsushima ..........................................................10
`
`Overview of Yu .........................................................................11
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`U.S. Patent 7,916,180
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`Analysis .....................................................................................12
`
`3.
`
`E.
`
`Ground 2: Claims 28 and 30 would have been obvious over
`Matsushima, Yu, and Weldy. ..............................................................61
`
`1.
`
`2.
`
`3.
`
`Overview of Weldy ...................................................................61
`
`Reasons to Combine Matsushima, Yu, and Weldy ..................62
`
`Analysis .....................................................................................67
`
`
`
`iii
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`
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`Ground 3: Claims 22-23, 28, and 30 would have been obvious over
`Choi, Labaziewicz, and Yu. ................................................................70
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`
`F.
`
`1.
`
`2.
`
`3.
`
`Overview of Choi ......................................................................70
`
`Overview of Labaziewicz .........................................................71
`
`Reasons to Combine Choi, Labaziewicz, and Yu .....................72
`
`4.
`
`Analysis .....................................................................................79
`
`VIII. DISCRETIONARY DENIAL IS INAPPROPRIATE .................................. 93
`
`A. No Basis For § 325(d) Denial .............................................................93
`
`B.
`
`No Basis for Fintiv Denial ..................................................................94
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`No evidence regarding a stay ....................................................95
`
`Parallel proceeding trial date ....................................................95
`
`Investment in the parallel proceeding .......................................96
`
`Overlapping issues with the parallel proceeding ......................97
`
`Petitioner is a defendant ............................................................97
`
`Other circumstances ..................................................................97
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`U.S. Patent 7,916,180
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`No Basis for General Plastic Denial. ..................................................98
`
`C.
`
`IX. CONCLUSION ............................................................................................. 98
`
`X. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8 ................................. 99
`
`A.
`
`B.
`
`C.
`
`Real Party-in-Interest ..........................................................................99
`
`Related Matters ....................................................................................99
`
`Lead and Back-up Counsel and Service Information .........................99
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`XI. CERTIFICATE OF WORD COUNT ......................................................... 101
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`PETITIONER’S EXHIBIT LIST
`
`U.S. Pat. No. 7,916,180 to Olsen et al. (“the ’180 patent”)
`
`Prosecution History of U.S. Pat. No. 7,916,180 (U.S. Application
`No. 11/788,279)
`Declaration of Mr. Michael Guidash under 37 C.F.R. § 1.68
`
`Curriculum Vitae of Mr. Michael Guidash
`
`U.S. 6,611,289 to Yu et. al
`U.S. 7,365,780 to Miyazaki
`
`JP Application Publication No. JP2003-319231 to Matsushima
`(Certified English Translation + Declaration + Japanese)
`
`U.S. 2005/0128323 to Choi
`Eastman Kodak Company, Kodak CMOS Image Sensors White
`Paper (November 10, 2000) (retrieved from
`https://web.archive.org/web/20010611235410/http://www.kodak.co
`m/US/plugins/acrobat/en/digital/ccd/cmos.pdf)
`
`U.S. 7,206,136 to Labaziewicz et al.
`U.S. 7,733,414 to Kobayashi
`
`Dave Litwiller, CCD vs. CMOS: Facts and Fiction, Photonics
`Spectra (January 2001)
`
`US Application Pub. No. 2004/0239771 to Habe
`EP Application Pub. No. EP0858208 to Weldy et al.
`
`IV’s Preliminary Infringement Contentions, Intellectual Ventures
`II, LLC v. Tesla, Inc., No. 6:24-cv-188-ADA (WDTX)
`
`Texas Instruments, TC255P 336- × 244-PIXEL CCD IMAGE
`SENSOR (March 2003)
`
`Ex.1001
`
`Ex.1002
`
`Ex.1003
`
`Ex.1004
`
`Ex.1005
`Ex.1006
`
`Ex.1007
`
`Ex.1008
`Ex.1009
`
`Ex.1010
`Ex.1011
`
`Ex.1012
`
`Ex.1013
`Ex.1014
`
`Ex.1015
`
`Ex.1016
`
`
`
`vi
`
`
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`IV’s Complaint, Intellectual Ventures II, LLC v. Tesla, Inc., No.
`6:24-cv-188-ADA (WDTX)
`Proposed Scheduling Order, Intellectual Ventures II, LLC v. Tesla,
`Inc., No. 6:24-cv-188-ADA (WDTX)
`Statistics on District Court Timing
`Interim Procedure for Discretionary Denials in AIA Parallel District
`Court Litigation, June 21, 2022
`Eastman Kodak Company, Solid State Image Sensors Terminology,
`Application Note, DS 00-001, Revision 0 (December 8, 1994)
`(https://web.archive.org/web/20030413064955/http://www.kodak.c
`om/global/plugins/acrobat/en/digital/ccd/applicationNotes/terminol
`ogy.pdf)
`US 7,830,435 to Guidash
`Eastman Kodak Company, Charge Coupled Device (CCD) Image
`Sensors, CCD Primer, MTD/PS-0218, Revision No. 1 (May 29,
`2001)
`(https://web.archive.org/web/20030422183725/http://www.kodak.c
`om/global/plugins/acrobat/en/digital/ccd/applicationNotes/chargeC
`oupledDevice.pdf)
`Szeliski, Image Mosaicing for Tele-Reality Applications (May
`1994)
`Mann et al., On Being ‘Undigital” with Digital Cameras: Extending
`Dynamic Range By Combining Differently Exposed Pictures (May
`1995)
`Debevec et al., Recovering High Dynamic Range Radiance Maps
`from Photographs (August 3, 1997)
`PCT Pub. No. WO2001/010110 to Stark
`Yang et al., A 640 x 512 CMOS Image Sensor with Ultrawide
`Dynamic Range Floating-Point Pixel-Level ADC, IEEE Journal of
`Solid-State Circuits, VOL. 34, NO. 12 (December 1999)
`CCD Electronic Shutters, Interactive Java Tutorial, October 22,
`2002
`(https://web.archive.org/web/20021028042044/https://micro.magne
`t.fsu.edu/primer/java/digitalimaging/ccd/shutter/index.html)
`vii
`
`Ex.1017
`
`Ex.1018
`
`Ex.1019
`Ex.1020
`
`Ex.1021
`
`Ex.1022
`Ex.1023
`
`Ex.1024
`
`Ex.1025
`
`Ex.1026
`
`Ex.1027
`Ex.1028
`
`Ex.1029
`
`
`
`
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`The Panorama Factory -- What is 35mm equivalent focal length
`(http://www.panoramafactory.com/equiv35/equiv35.html)
`Camera & Imaging Products Association, Guideline for Noting
`Digital Camera Specifications in Catalogs, October 11, 2005
`London etc., Photography, Eighth Edition, January 1, 2004
`American National Standards Institute (ANSI), ANSI/I3AIT
`10.7000-2004 American National Standard for Photography -
`Digital Still Cameras - Guidelines for Reporting Pixel-Related
`Specifications, June 24, 2004
`
`Eastman Kodak Company, Shutter Operations for CCD and CMOS
`Image Sensors, Application Node, MTD/PS-0259, Revision 1
`(October 23, 2001) (retrieved from
`https://web.archive.org/web/20030419002619/http://www.kodak.co
`m/global/plugins/acrobat/en/digital/ccd/applicationNotes/ShutterOp
`erations.pdf)
`RESERVED
`U.S. Pat. No. 4,831,403 to Ishida et al.
`U.S. Pat. No. 7,443,427 to Takayanagi
`RESERVED
`e2v Technologies, CCD Sensors Technical Note: Glossary of
`Terms (2003)
`Ralph E. Jacobson et al., The Manual of Photography: photographic
`and digital imaging, 9th Edition (2000)
`U.S. Pat. No. 6,215,597 to Duncan et al.
`O’Donnell, The Practical Use of the Exposure Triangle (retrieved
`from https://creativeraw.com/practical-use-exposure-triangle-
`explained/)
`U.S. Pat. No. 2,953,983 to Larson
`RESERVED
`
`Ex.1030
`
`Ex.1031
`
`Ex.1032
`Ex.1033
`
`Ex.1034
`
`Ex.1035
`Ex.1036
`Ex.1037
`Ex.1038
`Ex.1039
`
`Ex.1040
`
`Ex.1041
`Ex.1042
`
`Ex.1043
`Ex.1044-
`1045
`
`
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`
`Ex.1046
`
`Ex.1047
`Ex.1048
`Ex.1049
`Ex.1050
`
`Ex.1051
`
`Comparison of Provisional Application No. 60/604,854 and ’180
`Patent Specification
`Provisional Application No. 60/604,854, filed on August 25, 2004
`Provisional Application No. 60/695,946, filed on July 1, 2005
`Provisional Application No. 60/795,946 filed on April 28, 2006
`Prosecution History of U.S. Application No. 11/212,803
`(abandoned)
`U.S. Application No. 11/212,803 (published as US 2006/0054782)
`
`
`ix
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`I.
`
`Introduction
`
`IPR2025-00339 Petition
`U.S. Patent 7,916,180
`
`
`U.S. Patent No. 7,916,180 (the “’180 patent,” Ex.1001) is directed to a digital
`
`camera that simultaneously acquires image data via multiple channels having
`
`different fields of view (FOVs). As discussed in detail below, its claimed elements—
`
`namely, configuring a plurality of channels having different FOVs, independently
`
`controlling simultaneous data acquisition with the channels, and combining the
`
`acquired data—were well-known in digital imaging.
`
`Accordingly, pursuant to 35 U.S.C. §§ 311, 314(a), and 37 C.F.R. § 42.100,
`
`Tesla, Inc. (“Petitioner”) respectfully requests that the Board review and find
`
`unpatentable claims 1-3, 10-12, 22-25, 28, 30, and 32-33 (the “Challenged Claims”)
`
`of the ’180 patent.
`
`II. Certification of Grounds for Standing
`
`Petitioner certifies that the ’180 patent is available for inter partes review
`
`(IPR) and that Petitioner is not barred or estopped from requesting IPR of the
`
`patent’s claims.
`
`III. Note
`
`Petitioner cites to exhibits’ original page numbers, unless noted otherwise.
`
`Emphasis in quoted material has been added. Claim terms are presented in italics.
`
`
`
`1
`
`
`
`IV. The ’180 Patent
`Summary
`A.
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
`
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`The ’180 patent is directed to “digital cameras configured to simultaneously
`
`acquire image data via multiple channels having different fields of view [FOV].”
`
`Ex.1001, Abstract. In the digital camera of FIG. 4 below, each channel 260A-260D
`
`respectively includes an optics component 290A-290D and a sensor 292A-292D in
`
`a one-to-one relationship, and “provides a different FOV.” Ex.1001, Abstract, FIG.
`
`4, 6:31-33; Ex.1003, ¶¶54-56.
`
`Ex.1001, FIG. 4.
`
`
`
`Mr. Guidash provides a technical background of the ’180 patent. Ex.1003,
`
`¶¶22-55 (citing Ex.1001, 20:7-10; EX.1006, FIGS. 2-3, 5:56-60; Ex.1009, 2, 4, 9;
`2
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`Ex.1011, FIG. 3, 8:45-50; Ex.1012, 2, 4; Ex.1013, [0022], [0024]; Ex.1014,
`
`FIGS.1a-1c, 3, 5:14-20; Ex.1016, 1; Ex.1021, 17, 24; Ex.1022, 1:22-24; Ex.1023,
`
`FIGS. 7-8, 5-6, 10-11; Ex.1024, 3; Ex.1025, FIG. 8, 7; Ex.1026, 1; Ex.1027, 3:10-
`
`12; Ex.1028, 1821n.1; Ex.1029, 1; Ex.1034, 2-5; Ex.1039, 3; Ex.1040, FIG. 19.1,
`
`310; Ex.1042, 1; Ex.1043, FIGS. 2, 4).
`
`B.
`
`Prosecution History
`
`The ’180 patent claims priority to an abandoned parent application and three
`
`provisional applications. Ex.1001, 1; Exs.1047-1050 (prosecution histories of parent
`
`and provisional applications); Ex.1003, ¶¶57-59.
`
`During prosecution of the abandoned parent application, the Examiner
`
`rejected claims substantively different from the Challenged Claims based on
`
`combinations including Yu (Ex.1005).1 Ex.1050, 1-2, 18, 21, 527.
`
`During prosecution of the ’180 patent, the claims were allowed after multiple
`
`office actions and amendments, where the applicant identified the arrangement of
`
`the first and second channels having different FOVs comprising different angular
`
`widths as the distinguishing feature in the last response (see limitations [22.1]-[22.2]
`
`and [1.1.2] below). Ex.1002, 53, 90. Ex.1002, 57. Yu was never relied upon by the
`
`
`1 The different claims of the parent application are summarized in Section VIII.A
`
`n.3.
`
`
`
`3
`
`
`
`Office. Ex.1002, 199.
`
`C. Effective Filing Date
`
`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`The effective filing date of each of the Challenged Claims is no earlier than
`
`July 1, 2005, the filing date of Provisional Application 60/695,946 (“the ’946
`
`provisional,” Ex.1048). Ex.1003, ¶¶62-66.
`
`For a claim in a later-filed application to be entitled to the filing date of an
`
`earlier application, the earlier application must provide written description support
`
`for the claimed subject matter. Anascape, Ltd. v. Nintendo of Am. Inc., 601 F.3d
`
`1333, 1337 (Fed. Cir. 2010).
`
`The Challenged Claims are not entitled to the filing date of the earliest
`
`Provisional Application No. 60/604,854 (the “’854 provisional,” Ex.1047), because,
`
`as confirmed by Mr. Guidash, no written description exists in the ’854 provisional
`
`for (1) providing multiple channels having different FOVs (a limitation of all
`
`Challenged Claims); and (2) configuring multiple optics components relative to
`
`multiple sensors respectively to form these multiple channels (limitations of claims
`
`22-25, 28, 30, and 32-33). Ex.1003, ¶64; Ex.1046 (comparison of ’180 patent
`
`specification and ’854 provisional). As shown in FIG. 3 below, the ’854 provisional
`
`simply describes “a different lens over each of the different arrays” of a single sensor
`
`210, where the different lenses 230A-D are “tailored for the respective wavelength
`
`of the respective array [210A-D].” Ex.1047, 5, 8 (Specification, 2, 5). There is no
`4
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`disclosure for multiple sensors—only a single “sensor 210.” See also Ex.1047, 16-
`
`19 (claims reciting a single sensor). Further, the ’854 provisional does not provide
`
`support for multiple channels having different FOVs, or configuring multiple optics
`
`components relative to multiple sensors respectively to form multiple channels with
`
`different FOVs, much less combining data captured with the channels with different
`
`FOVs. Ex.1003, ¶¶63-64.
`
`Ex.1047, FIG. 3.
`
`
`
`Accordingly, the effective filing date of each of the Challenged Claims is no
`
`earlier than July 1, 2005, the filing date of the ’946 provisional (Ex.1048). For
`
`avoidance of doubt, only Ground 3 depends on this priority analysis. Regardless, the
`
`analysis of Grounds 1-2 remains the same if it is argued that the effective filing date
`5
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`of any Challenged Claim is August 25, 2004, the filing date of the ’854 provisional.
`
`The prior art in Grounds 1-2 predates the ’854 provisional. Ex.1003, ¶¶65-66.
`
`V. Level of Ordinary Skill in the Art
`
`A person of ordinary skill in the art at and before the earliest priority date
`
`(August 25, 2004) or earliest effective filing date of the ’180 patent (July 1, 2005)
`
`(“POSITA”) would have had a bachelor’s degree in electrical engineering, computer
`
`engineering, computer science, or a related field and 2-3 years of experience in
`
`digital imaging systems. Less experience may be necessary with additional
`
`education, and likewise, less education may be necessary with additional work
`
`experience. Ex.1003, ¶¶16-19.
`
`VI. Claim Construction
`
`No claim term other than the terms identified below requires construction.
`
`Ex.1003, ¶¶67-76.
`
`A. “simultaneous data acquisition with each of the first and second
`channels during a frame” (claim 22)
`
`A POSITA would have understood that “simultaneous data acquisition with
`
`each of the first and second channels during a frame” means “simultaneous data
`
`acquisition of an image frame with each of the first and second channels during a
`
`period of time.” Ex.1003, ¶69.
`
`The ’180 patent defines “frame” as a physical component of a camera.
`
`
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`6
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`Ex.1001, 22:8-9. A POSITA would have understood that this description does not
`
`apply to the claimed “…during a frame,” because a physical component does not
`
`have a time period for data acquisition. Ex.1003, ¶70.
`
`This construction is supported by the specification. Application 11/212,803,
`
`incorporated by reference in the ’180 patent, provides that “if the instruction ‘Single
`
`Frame Capture’ is received, the camera interface may initiate capture of a single
`
`frame.” Ex.1051, [0836]; Ex.1001, 1:7-15. A POSITA would have understood that
`
`“during a frame” refers to during a period of time that data for an image frame is
`
`acquired. Ex.1003, ¶71. Regarding data acquisition, the ’180 patent states, “[t]he
`
`electrical operation of each camera channel is independent of the other camera
`
`channels and multiple fields of view can be acquired simultaneously.” Ex.1001,
`
`3:51-54. Thus, a POSITA would have understood that during the period of time,
`
`each of the first and second channels acquires data for an image frame
`
`simultaneously. Ex.1003, ¶¶71-72.
`
`This construction is supported by the surrounding claim language. Claim 22
`
`recites “independently controlling simultaneous data acquisition with each of the
`
`first and second channels during a frame,” and “combining data received during
`
`the frame from one or more of the first and second channels to provide an image.”
`
`A POSITA would have understood that during a period of time when data for an
`
`image frame is acquired, simultaneous data acquisition of an image frame with each
`7
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`of the first and second channels is performed, and the acquired data (data received
`
`during the frame from one or more of the first and second channels) is combined to
`
`provide an image. Ex.1003, ¶73.
`
`B. “data of a frame” (claim 1)
`
`A POSITA would have understood that “data of a frame” means “data of an
`
`image frame.” Ex.1003, ¶74.
`
`A POSITA would have understood that the ’180 patent’s description of
`
`“frame” as a physical component (Ex.1001, 22:8-9) does not apply to the claimed
`
`“data of a frame,” because a physical component does not have data to be combined
`
`to provide an image as recited in the surrounding claim language. Ex.1001, claim 1;
`
`Ex.1003, ¶75.
`
`This construction is supported by the specification. The ’180 patent describes
`
`that “[t]he data from all sensors can be digitally combined to provide a much greater
`
`dynamic range within one frame of digital camera data.” Ex.1001, 20:19-21. A
`
`POSITA would have understood that one frame of digital camera data refers to data
`
`of an image frame. Ex.1001, 9:1-8 (image processor “generate[s] or composite[s] an
`
`image based on data from one or more of the camera channels,” particularly “the
`
`images from the first and second camera channels”); Ex.1003, ¶76.
`
`
`
`8
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`
`
`VII. The Challenged Claims Are Unpatentable
`A. Challenged Claims
`
`IPR2025-00339 Petition
`U.S. Patent 7,916,180
`
`
`Petitioner challenges claims 1-3, 10-12, 22-25, 28, 30, and 32-33 of the ’180
`
`patent.2 As discussed at IV.C, the effective filing date of each challenged claim is
`
`no earlier than July 1, 2005.
`
`B. Prior Art Patents and Printed Publications
`
`1. JP2003-319231
`
`(“Matsushima”)
`
`(Ex.1007,
`
`including certified English
`
`translation, certification, and original Japanese publication); published
`
`November 7, 2003; prior art under 35 U.S.C. §§102(a) and 102(b).
`
`2. U.S. 6,611,289 (“Yu”) (Ex.1005); filed January 15, 1999; issued August 26,
`
`2003; prior art under §§102(a)-(b) and 102(e).
`
`3. EP Application Pub. No. EP0858208 to Weldy et al. (“Weldy”) (Ex.1014),
`
`published August 12, 1998; prior art under §§102(a) and 102(b).
`
`4. US Pub. 2005/0128323 (“Choi”) (Ex.1008), filed Nov. 1, 2004; published June
`
`16, 2005; prior art under §§102(a) and (e).
`
`5. US 7,206,136 (“Labaziewicz”) (Ex.1010), filed Feb. 18, 2005; published
`
`August 24, 2006; prior art under §102(e).
`
`
`2 The pre-AIA statutory framework applies to the ’180 patent.
`
`
`
`9
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`
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`C. Statutory Grounds for Challenges
`
`IPR2025-00339 Petition
`U.S. Patent 7,916,180
`
`
`This Petition, supported by the declaration of Mr. Guidash (Ex.1003), requests
`
`cancellation of the Challenged Claims under the following Grounds:
`
`Ground
`
`Claim
`
`Pre-AIA § 103 Basis
`
`#1
`
`#2
`
`#3
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`1-3, 10-12, 22, 24-25,
`28, 30, 32-33
`28, 30
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`Matsushima and Yu
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`Matsushima, Yu, and Weldy
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`22-23, 28, 30, 33
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`Choi, Labaziewicz, and Yu
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`D. Ground 1: Claims 1-3, 10-12, 22, 24-25, 28, 30, and 32-33
`would have been obvious over Matsushima and Yu.
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`1. Overview of Matsushima
`Matsushima discloses a “digital camera [that] has two independent imaging
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`systems,” with “a first image imaging system including a first image sensor…and
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`a first lens for forming an image of the subject,” and “a second imaging system
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`including a second image sensor…and a second lens with a focal length longer
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`than the first lens for forming an image of the subject.” Ex.1007, [0001], [Claim 1],
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`[0017]; see also id., [0008], [0020]. Matsushima’s digital camera “prevent[s]
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`unnatural boundary regions even when a telephoto captured image is combined in
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`the center of a wide-angle captured image.” Ex.1007, [0007]; Ex.1003, ¶81.
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`Ex.1007, FIG. 1.
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`2. Overview of Yu
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`Yu is directed to digital cameras that “use multiple image sensors with
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`multiple lenses.” Ex.1005, Yu, Abstract. In FIG. 3, below, Yu’s “digital camera uses
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`four image sensors, each having its own lens.” Id., 2:40-44. Ex.1003, ¶82.
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`U.S. Patent 7,916,180
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`Ex.1005, FIG. 3
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`Yu explains that “each of the image sensors is respectively and
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`independently controlled to expose to the same imaging target.” Ex.1005, 9:66-
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`10:2; id., 6:52-58 (“control circuits…receive respectively the control signals …[and]
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`each...independently and respectively control image sensors”); 12:16-18, 9:50-52.
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`Yu explains there are “many other causes” that may need to control image sensors
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`independently, “such as gain and offset controls.” Ex.1005, 6:58-61; Ex.1003, ¶83.
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`3. Analysis
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` Claim 22
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`[22.0] A method comprising:
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`Matsushima discloses or renders obvious [22.0]. Ex.1003, ¶¶84-86.
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`As shown in FIG. 7 below, Matsushima describes a method (control routine)
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`for configuring two independent imaging systems, capturing images therefrom, and
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`U.S. Patent 7,916,180
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`performing image synthesis to generate an image with improved quality (e.g.,
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`improved resolution, expanded dynamic range). Ex.1007, FIG. 7, [0062]-[0069]
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`(describing control routine in FIG. 7); Ex.1003, ¶85.
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`Ex.1007, FIG. 7.
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`
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`Thus, Matsushima discloses or renders obvious [22.0]. Ex.1003, ¶86.
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`13
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`[22.1] configuring a first optics component relative to a first image sensor to
`form a first channel having a first field of view (FOV) that comprises a first
`angular width of a scene;
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`Matsushima discloses or renders obvious [22.1]. Ex.1003, ¶¶87-90.
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`As shown in FIGS. 1, 2(A) and 3(A) below, Matsushima discloses configuring
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`a first optics component (setting a first imaging optics 14A including first lens group
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`19A) relative to a first image sensor (first image sensor 18A) to form a first channel
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`(first imaging system 12A) having a first field of view (FOV) (shown in annotation
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`in FIGS. 2(A) and 3(A)) that comprises a first angular width (shooting angle α of
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`lens group 19A) of a scene (e.g., scene of FIG. 3). Ex.1007, [Claim 1], [0017],
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`[0022], [0020] (“configuration of a digital camera” including lens group 19A with
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`a “shooting angle α”), [Claim 3] (“a means for setting the shooting angle”), [0014]
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`(“the digital camera may be configured to further comprise a means for setting the
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`shooting angle”); Ex.1003, ¶88.
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`U.S. Patent 7,916,180
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`Ex.1007, FIG. 1, annotated; Ex.1003, ¶88.
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`U.S. Patent 7,916,180
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`Ex.1007, FIGS. 2 and 3, annotated; Ex.1003, ¶88.
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`Matsushima describes configuring a first optics component (setting the first
`
`imaging optics 14A including first lens group 19A) to operate with a first image
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`sensor (first image sensor 18A) to form a first channel having a first field of view
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`(FOV) according to the defined shooting angle α, with the following relationship:
`
`first FOV with shooting angle α =2𝑡𝑡𝑡𝑡𝑡𝑡−1(𝐾𝐾12𝑓𝑓1),
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`where K1 is the diagonal of the sensor format of image sensor 18A, and f1 is the focal
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`length of the first optics 14A. Ex.1007, [0017], [Claim 3], [0014], [0020]; Ex.1003,
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`¶89. Such setting of a lens relative to the sensor to form a channel having a specific
`
`FOV was well-known in the art. Ex.1040, 48 (“The focal length of a lens also
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`determines the angle of the field of view (FOV) relative to a…sensor format. The
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`FOV is defined as the angle subtended at the (distortion-free) lens by the diagonal
`
`(K) of the format when the lens is focused on infinity.”), FIG. 4.13 (reproduced
`
`below, illustrating “Field (angle) of view (FOV) of a lens related to format
`
`dimension”); Ex.1003, ¶89 (explaining well-known knowledge of setting a lens
`
`relative to an image sensor to form a channel having a specific FOV).
`
`Ex.1040, FIG. 4.13.
`
`
`
`Thus, Matsushima discloses or renders obvious [22.1]. Ex.1003, ¶90.
`
`[22.2] configuring a second optics component relative to a second image sensor
`to form a second channel having a second FOV that comprises a second angular
`width of the scene, wherein the first and second angular widths are different;
`
`Matsushima discloses or renders obvious [22.2]. Ex.1003, ¶¶91-94.
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`U.S. Patent 7,916,180
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`As shown in FIG. 1 and FIGS. 2(B) and 3(B) below, Matsushima discloses
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`configuring a second optics component (setting a second imaging optics 14B
`
`including second lens group 19B) relative to a second image sensor (second image
`
`sensor 18B) to form a second channel (second imaging system 12B) having a second
`
`FOV (shown in annotation in FIGS. 2(B) and 3(B)) that comprises a second angular
`
`width (shooting angle β of lens group 19B) of the scene (e.g., scene of FIG. 3), where
`
`the first and second angular widths are different (shooting angle β is narrower than
`
`shooting angle α). Ex.1007, [Claim 1], [0017] (“configuration of a digital camera”
`
`of FIG. 1 including “a second imaging system 12B”), [0022], [0020] (“configuration
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`of a digital camera” of FIG. 1 including lens group 19B that “is a telephoto single
`
`focal length lens whose shooting angle β is narrower than the shooting angle α
`
`of lens group 19A”); [Claim 3] (“a means for setting the shooting angle”), [0014];
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`Ex.1003, ¶92.
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`Ex.1007, FIG. 1, annotated; Ex.1003, ¶92.
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`Ex.1007, FIGS. 2 and 3, annotated; Ex.1003, ¶92.
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`Matsushima discloses setting a second optics component (second imaging
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`optics 14B including second lens group 19B) to operate with a second image sensor
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`(second image sensor 18B) to form a channel having a second FOV with shooting
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`angle β to as follows:
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`second FOV with shooting angle β =2𝑡𝑡𝑡𝑡𝑡𝑡−1(𝐾𝐾22𝑓𝑓2),
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`where K2 is the diagonal of the sensor format of image sensor 18B, and f2 is the focal
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`length of the second optics 14B. Ex.1007, [0020]; Ex.1003, ¶93 (explaining the well-
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`U.S. Patent 7,916,180
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`known knowledge of setting a lens relative to an image sensor to provide an FOV,
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`citing Ex.1040, FIG. 4.13).
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`Thus, Matsushima discloses or renders obvious [22.2]. Ex.1003, ¶94.
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`[22.3] independently controlling simultaneous data acquisition with each of the
`first and second channels during a frame; and
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`Matsushima alone discloses or renders obvious [22.3]. Alternatively,
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`Matsushima in view of Yu renders obvious [22.3]. Ex.1003, ¶¶95-116.
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`i. Matsushima alone discloses or renders obvious [22.3].
`As shown in FIGS. 1-3 below, Matsushima discloses or renders obvious
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`independently controlling (independent control of automatic exposure including
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`independently controlling charge accumulation times of image sensors 18A and
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`18B) simultaneous data acquisition with each of the first and second channels
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`during a frame (during a period of time, simultaneous acquisition of data for image
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`62A with first imaging system 12A and data for image 62B with second imaging
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`system 12B, “when the release button is ‘fully press[ed]’”). Ex.1007, [0031] (“CPU
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`30 performs various calculations such as focus evaluation calculations and AE
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`[automatic exposure adjustment] calculations based on the image signals outputted
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`from CCD 18A and CCD 18B, and the driving circuits 52A and 52B of the imaging
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`lenses 15A and 15B, the focus lenses 16A and 16B, and the apertures 17A and 17B
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`are controlled based on these calculations.”); Ex.1003, ¶¶96-102 (explaining that a
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`U.S. Patent 7,916,180
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`POSITA would have understood that Matsushima’s independent control of charge
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`accumulation times is the independent control of integration times for image
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`acquisition as described in the ’180 patent, citing Ex.1001, 20:34-36; Ex.1036, 14:1-
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`3, 25:41-42; Ex.1037, 3:35, 3:52, 4:16).
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`Ex.1007, FIG. 1, annotated; Ex.1003, ¶96.
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`U.S. Patent 7,916,180
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`Ex.1007, FIGS. 2 and 3, annotated; Ex.1003, ¶96.
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`Specifically, Matsushima discloses or renders obvious that images 62A and
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`62B are acquired by simultaneous data acquisition with each of the first and second
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`channels during a frame, because Matsushima describes that image 62B is a scaled-
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`up image of the center of image 62A and therefore images 62A and 6B are captured
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`at the same time to avoid image discrepancies due to motion or other artifacts.
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`Ex.1007, [0021] (“the image captured by the second imaging system 12B is the
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`scaled-up captured image 62B at the center of FIG. 3(A)”); Ex.1003, ¶97
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`(explaining that for image 62B to be a “scaled-up image” of the center of image 62A
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`as described in Matsushima, images 62A and 62B are captured at the same time
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`during a frame, because otherwise, an image frame 62B of a scene captured at a
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`IPR2025-00339 Petition
`U.S. Patent 7,916,180
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`different time would change (e.g., with moving objects, different lighting conditions)
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`and therefore does not provide a “scaled-up” image of 62A); see also Ex.1007,
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`[Claim 1] (“a first imaging system including a first image sensor for imaging a
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`subject…; a second imaging system including a second image sensor for imaging
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`the subject”). As shown in FIGS. 2-3 above, Matsushima describes performing
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`simultaneous data acquisition of the same subject during a frame where control
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`circuits are “driven synchronously by timing signals” for capturing image 62A (an
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`image frame from the first channel) and image 62B (image frame from the second
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`channel)
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