Uniloc 2017 LLC

Patent Trials and Appeals Board

Jan 5, 2021

IPR2019-01270 (P.T.A.B. Jan. 5, 2021)

Trials@uspto.gov Paper 26
571-272-7822 Date: January 5, 2021

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

SLING TV LLC,
Petitioner,

v.

UNILOC 2017 LLC,
Patent Owner.
____________

IPR2019-01270
Patent 6,519,005 B2
____________

Before JAMESON LEE, KEVIN F. TURNER, and
THOMAS L. GIANNETTI, Administrative Patent Judges.

TURNER, Administrative Patent Judge.

JUDGMENT
Final Written Decision
Determining All Challenged Claims Unpatentable
35 U.S.C. § 318(a)
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We have jurisdiction to conduct this inter partes review under
35 U.S.C. § 6. This Final Written Decision is issued pursuant to 35 U.S.C.
§ 318(a) and 37 C.F.R. § 42.73. For the reasons discussed herein, we
determine that a preponderance of the evidence shows that claims 1−16 and
39−42 (“the Challenged Claims”) of U.S. Patent No. 6,519,005 B2
(Ex. 1001, “the ’005 Patent”) are unpatentable.
I. INTRODUCTION
A. Summary of Procedural History
Sling TV L.L.C. (“Petitioner”) filed a Petition (Paper 2, “Pet.”)
requesting inter partes review of the Challenged Claims. Pet. 1.
We instituted an inter partes review of the Challenged Claims on all grounds
of unpatentability asserted in the Petition. Paper 11 (“Inst. Dec.”).
Thereafter, Patent Owner filed a Patent Owner Response (Paper 16, “PO
Resp.”). Petitioner filed a Reply to the Patent Owner Response (Paper 17,
“Pet. Reply”), to which Patent Owner filed a Sur-reply (Paper 18, “PO Sur-
reply”).
Oral argument was held on October 7, 2020, and a transcript of the
hearing appears in the record. Paper 25 (Tr.). We have jurisdiction under
35 U.S.C. § 6. This Final Written Decision is issued pursuant to 35 U.S.C.
§ 318(a) and 37 C.F.R. § 42.73 (2017). Petitioner bears the burden of
proving unpatentability of the Challenged Claims by a preponderance of the
evidence, and the burden of persuasion never shifts to Patent Owner. See
35 U.S.C. § 316(e) (2012); 37 C.F.R. § 42.1(d) (2017); Dynamic Drinkware,
LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015).
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B. Related Proceedings
The parties indicate that the ’005 Patent is the subject of 23 pending
district court cases, with 12 of those cases indicated as still pending. See
Pet. vii−ix; Paper 3, 2. The following post grant proceedings also involve
the ’005 Patent: (1) IPR2019-01126, filed May 28, 2019 by petitioner
Unified Patents, LLC (instituted: December 10, 2019; Final Written
Decision, finding all challenged claims unpatentable: December 8, 2020)
and (2) IPR2019-01584, filed September 9, 2019 by petitioner Google LLC
(institution denied: March 24, 2020; rehearing denied: October 16, 2020).
C. The ’005 Patent
The ’005 Patent is generally related to digital video compression, and
more particularly, to a motion estimation method and search engine for a
digital video encoder. Ex. 1001, 1:6−8. The ’005 Patent is titled “Method
of Concurrent Multiple-Mode Motion Estimation for Digital Video” and
discloses improved methods of digital video encoding. Id. at code (54), Abs.
With respect to the prior art Moving Pictures Expert Group (MPEG)
processes, the ’005 Patent explains that audio and video data in the form of a
multimedia data stream are encoded/compressed prior to transmission “in
order to minimize the bandwidth required to transmit this digital video data
stream for a given picture quality.” Id. at 1:12−17. The ’005 Patent
explains that, in accordance with the MPEG standards (MPEG-2 and its
predecessor, MPEG-1), “the audio and video data comprising a multimedia
data stream (or ‘bit stream’) are encoded/compressed in an intelligent
manner using a compression technique generally known as ‘motion
coding,’” to avoid transmitting each video frame in its entirety. Id. at
1:40−47.
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The ’005 Patent discusses “predictive” video frames using reference
or anchor frames looking at macroblocks of 16x16 pixel regions. Id. at
1:61−65, Figs. 1A, 1B. For each macroblock, the system searches for a
similar portion of the reference, and this results in a motion vector that
identifies the position of the “best match” within reference frames relative to
the position of the macroblock in the frame being encoded. Id. at 2:18−47.
The ’005 Patent details six standard ways to perform the motion estimation
process, called “prediction modes,” with different modes being applied
based on the “picture structure.” Id. at 9:36−40. For “frame” picture
structures, the entire frame is considered a single picture, while for “field”
picture structures, the frame is divided into a top field and a bottom field.
Id. at 7:27−61. Two of these different prediction modes are illustrated in
Figures 2A and 2B and are reproduced below:

Figures 2A and 2B of the ’005 Patent are diagrams that illustrate motion
estimation for frame pictures using frame and field predictions.
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In Figure 2A, “frame prediction” will treat the macroblock like a
single 16x16 block, and the motion estimation search system will search for
the 16x16 pixel portion of the reference picture that is the best match (e.g.,
minimizes the difference between the macroblock and a given portion of the
reference picture), whereas Figure 2B shows “field prediction” for a “frame”
picture, with the macroblock and the anchor picture divided into odd and
even numbered rows of pixels (referred to as a “top” field, and a “bottom”
field), and the system will try to find the best match for each of the two
fields. Id. at 7:27−60. The ’005 Patent discloses at least six prediction
modes. Id. at 9:36−38, 15:38−46.
The ’005 Patent provides that conventional systems required a single
prediction mode to be specified, without knowing which might be optimum,
but the disclosed processes allow for the determination of the optimum
prediction mode while performing motion estimation and generating motion
vectors, without the need for pre-selection of a mode. Id. at 3:7−15, 40−49.
The ’005 Patent describes a “scheme for concurrently searching . . . each of
a plurality of motion prediction modes” using a single search, which allows
for optimum selection between the different options, i.e., different prediction
modes. Id. at 3:53−61, 9:28−35. The ’005 Patent also provides that because
the error metrics for different prediction modes are mathematically related to
one another, a single search can “concurrently” calculate the error metrics
for multiple prediction modes. Id. at 3:54−67, 8:14−23.
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D. Illustrative Claim
Of the Challenged Claims, claims 1, 39, and 41 are independent.
Claims 2−16 ultimately depend from claim 1; claim 40 depends from claim
39; and claim 42 depends from claim 41. Claim 1 is illustrative:
1. A method for motion coding an uncompressed digital video
data stream, including the steps of:
[1A] comparing pixels of a first pixel array in a picture
currently being coded with pixels of a plurality of second
pixel arrays in at least one reference picture and [1B]
concurrently performing motion estimation for each of a
plurality of different prediction modes in order to determine
which of the prediction modes is an optimum prediction
mode;
[1C] determining which of the second pixel arrays constitutes
a best match with respect to the first pixel array for the
optimum prediction mode; and,
[1D] generating a motion vector for the first pixel array in
response to the determining step.
Ex. 1001, 15:9–22 (bracketed matter added).
E. The Asserted Grounds of Unpatentability
Petitioner asserts the following grounds of unpatentability (Pet. 2)1:
Claim(s) Challenged 35 U.S.C. § Basis
1−16, 39−42 102 Ishihara2

1 The claims at issue have an effective filing date of April 30, 1999, which is
prior to March 16, 2013, the effective date of the Leahy-Smith America
Invents Act, Pub. L. No. 112-29, 125 Stat. 284 (2011) (“AIA”), and, thus,
we apply the pre-AIA version of 35 U.S.C. § 103.
2 K. Ishihara et al., A Half-pel Precision MPEG2 Motion-Estimation
Processor with Concurrent Three-Vector Search, 30 (12) IEEE J. of Solid-
State Circuits 1502−09 (Dec. 1995) (Ex. 1006, “Ishihara”).
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Claim(s) Challenged 35 U.S.C. § Basis
1−16, 39−42 103 Ishihara, Ishihara7983
1−16, 39−42 103 Ishihara, Ishihara4864
1−16, 39−42 103 Ishihara, Bellifemine5
Petitioner also relies on multiple declarants in addition to the material
found in the Petition. Specifically, Petitioner relies on the testimony of Dr.
James A. Storer (Ex. 1002) to support the contentions in the Petition. In
addition, Petitioner cites to declarations of Gerard P. Grenier (Ex. 1026) and
Dr. Sylvia D. Hall-Ellis (Ex. 1027) with respect to the publication of
Ishihara by the Institute of Electrical and Electronics Engineers (IEEE) to
assert that it was published, cataloged, and indexed for public availability.
Pet. 12−14 (citing Ex. 1024, 1, 4; Ex. 1025 1; Ex. 1026 ¶¶ 1−12; Ex. 1027
¶¶ 1−51; Ex. 1028 ¶¶ 1−7). Neither Petitioner nor Patent Owner filed any
additional declaratory evidence subsequent to the Institution Decision.
II. ANALYSIS OF PETITION
In our analysis of Petitioner’s unpatentability contentions with respect
to the Challenged Claims, we next address the applicable principles of law;
the level of ordinary skill in the art; the construction of claim terms; the
scope and content of the asserted prior art; and then analyze Petitioner’s

3 U.S. Patent No. 6,674,798 B2, issued January 6, 2004 (Ex. 1011,
“Ishihara798”).
4 U.S. Patent No. 5,949,486, issued September 7, 1999 (Ex. 1012,
“Ishihara486”).
5 PCT Pub. No. WO98/42137, published September 24, 1998 (Ex. 1016,
“Bellifemine”).
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contentions with respect to each alleged ground of unpatentability for
purposes of determining whether Petitioner shows by a preponderance of the
evidence the unpatentability of the Challenged Claims.
A. Principles of Law
Petitioner has asserted each of the Challenged Claims of the
’005 Patent is unpatentable under 35 U.S.C. §§ 102 and/or 103. A claim is
unpatentable under 35 U.S.C. § 102 if a single prior art reference expressly
or inherently describes each and every limitation set forth in the claim. See
Perricone v. Medicis Pharm. Corp., 432 F.3d 1368, 1375 (Fed. Cir. 2005);
Verdegaal Bros., Inc. v. Union Oil Co. of Cal., 814 F.2d 628, 631 (Fed. Cir.
1987).
A patent claim is unpatentable as obvious “if the differences between
the claimed invention and the prior art are such that the claimed invention as
a whole would have been obvious before the effective filing date of the
claimed invention to a person having ordinary skill in the art to which the
claimed invention pertains.” 35 U.S.C. § 103. An invention “composed of
several elements is not proved obvious merely by demonstrating that each of
its elements was, independently, known in the prior art.” KSR Int’l Co. v.
Teleflex Inc., 550 U.S. 398, 418 (2007).
The question of obviousness is resolved on the basis of underlying
factual determinations, including: (1) the scope and content of the prior
art; (2) any differences between the claimed subject matter and the prior
art; (3) the level of skill in the art; and (4) objective evidence of
nonobviousness. Graham v. John Deere Co. of Kansas City, 383 U.S. 1,
17–18 (1966). An obviousness determination “cannot be sustained by mere
conclusory statements; instead, there must be some articulated reasoning
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with some rational underpinning to support the legal conclusion of
obviousness.” KSR, 550 U.S. at 418 (quoting In re Kahn, 441 F.3d 977, 988
(Fed. Cir. 2006)); see In re Magnum Oil Tools Int’l, Ltd., 829 F.3d 1364,
1380 (Fed. Cir. 2016). Rather, “it can be important to identify a reason that
would have prompted a person of ordinary skill in the relevant field to
combine the elements in the way the claimed new invention does.”
KSR, 550 U.S. at 418.
B. Level of Ordinary Skill in the Art
In determining the level of ordinary skill in the art, various factors
may be considered, including the “type of problems encountered in the art;
prior art solutions to those problems; rapidity with which innovations are
made; sophistication of the technology; and educational level of active
workers in the field.” In re GPAC, Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995)
(quotation omitted).
Petitioner’s declarant, Dr. Storer, testifies that a person of ordinary
skill in the art in the context of the ’005 Patent would have been “a person
with a bachelor’s degree in electrical engineering, computer engineering,
computer science, or a similar field with at least two years of experience in
data compression or a person with a master’s degree in electrical
engineering, computer science, or a similar field with a specialization in data
compression.” Ex. 1002 ¶ 49. Patent Owner does not challenge this
assessment, nor does Patent Owner offer “a competing definition for
POSITA.” PO Resp. 8.
As we indicated in our Institution Decision, to the extent that
Petitioner’s assessment uses the open ended “at least” modifiers to make the
assessment open ended, we remove those modifiers to obtain definite
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amounts of education and experience. Inst. Dec. 15. We continue to note
that Petitioner’s assessment appears consistent with the level of ordinary
skill in the art at the time of the invention as reflected in the prior art in the
instant proceeding. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed.
Cir. 2001). For purposes of this Decision, we continue to apply Dr. Storer’s
assessment of the level of ordinary skill in the art.
C. Claim Construction
We apply the same claim construction standard articulated in Phillips
v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). See Changes to
the Claim Construction Standard for Interpreting Claims in Trial
Proceedings Before the Patent Trial and Appeal Board, 83 Fed. Reg. 51,340,
51358 (Oct. 11, 2018) (amending 37 C.F.R. § 42.100(b) effective November
13, 2018) (now codified at 37 C.F.R. § 42.100(b) (2019)). Petitioner
acknowledges this standard. Pet. 16. Under Phillips, claim terms are
generally afforded “their ordinary and customary meaning.” Phillips,
415 F.3d at 1312. “[T]he ordinary and customary meaning of a claim term
is the meaning that the term would have to a person of ordinary skill in the
art in question at the time of the invention.” Id. at 1313. “[T]he person of
ordinary skill in the art is deemed to read the claim term not only in the
context of the particular claim in which the disputed term appears, but in the
context of the entire patent, including the specification.” Phillips at 1313.
Only terms that are in controversy need to be construed, and then only to the
extent necessary to resolve the controversy. Vivid Techs., Inc. v. Am. Sci. &
Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999).
Petitioner seeks explicit claim construction of multiple terms:
“concurrently perform[ing]/[s] motion estimation,” “concurrently,” and in
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the context of dependent claims 7 and 12, “optimum,” and “a best match.”
Pet. 16–25 (citing Ex. 1002 ¶¶ 103–130). With respect to many of the
discussed terms, Petitioner discusses and contrasts with the claim
constructions proffered in the Unified IPR. Id. at 24–25. Patent Owner
indicates that “the Board need not construe any claim term in a particular
manner in order to arrive at the conclusion that the Petition is substantively
deficient,” while acknowledging that it “provides arguments below on the
scope of certain claim terms.” PO Resp. 11 (citing Nidec Motor Corp. v.
Zhongshan Broad Ocean Motor Co. Ltd., 868 F.3d 1013, 1017 (Fed. Cir.
2017)). We discuss each of Petitioner’s constructions below, for sake of
completeness, having adopted and continuing to adopt those constructions
for purposes of this decision. See Inst. Dec. 9–14.
1. “concurrently perform[ing]/[s] motion estimation [for]/[using] each
of a plurality of different [motion estimation] prediction modes”
Independent claim 1 recites, in part, “concurrently performing motion
estimation for each of a plurality of different prediction modes,” with
independent claims 39 and 41 each reciting “concurrently performs motion
estimation using each of a plurality of different motion estimation prediction
modes,” and “concurrently performing motion estimation using each of a
plurality of different motion estimation prediction modes,” respectively.
Taken together, Petitioner asserts that these claim limitations would have
been understood as “performing motion estimation according to each of a
plurality of prediction modes during the same search operation for a given
macroblock, without performing a separate search on the same macroblock
for each such mode.” Pet. 16 (citing Ex. 1002 ¶¶ 103–111).
Petitioner further asserts that one of ordinary skill in the art would
have understood that performing motion estimation in a plurality of different
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prediction modes was well-known, and that the process of “performing
motion estimation” (for all prediction modes) consists of performing a
“search” of a reference (or anchor) picture, wherein the macroblock being
coded is compared to blocks in the reference picture to find a “best match”
within a search range and the position of the best match relative to
macroblock being encoded constitutes the motion vector. Pet. 16–17 (citing
Ex. 1001, 1:40–55, 2:49–3:24; Ex. 1002 ¶¶ 59–66, 68–73, 76, 79–81, 105;
Ex. 1005 ¶¶ 22–23; Ex. 1017, 7, 13; Ex. 1019 § 7.6.1; Ex. 1009, 154; Ex.
1010, 14–15). Petitioner also asserts that one of ordinary skill in the art
would have understood that that the word “concurrently” in its plain and
ordinary meaning generally means “at the same time” or “simultaneously,”
and, in the context of the claims, would have been understood to refer to
performing motion estimation in each of the different prediction modes for a
given macroblock during the same search operation—i.e., without
performing a separate search on the same macroblock for each different
prediction mode, consistent with the Specification. Id. at 17–18 (citing Ex.
1001, 3:54–61, 8:9–13; Ex. 1002 ¶¶ 106–108).
Patent Owner asserts that no “comprehensive construction” is
necessary to resolve the controversy. PO Resp. 11. We adopt Petitioner’s
proposed claim constructions of “concurrently perform[ing]/[s] motion
estimation [for]/[using] each of a plurality of different [motion estimation]
prediction modes” as discussed above, for purposes of this decision as we
determine that the construction is consistent with portions of the
Specification cited.
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2. “concurrently performing motion estimation”
Dependent claims 7 and 12 recite the different prediction modes
explicitly, reciting 6 and 4 modes respectively, breaking them out according
to types of pictures. Petitioner asserts that the proper construction of those
claims requires that if the macroblock being encoded is of one type, i.e., a
“frame picture” or a “field picture,” then motion estimation is performed for
each of the prediction modes of that type concurrently. Pet. 19. Petitioner
further asserts that the plain language of claims 7 and 12 would seem to
require the concurrent performance of all the prediction modes enumerated
therein, but that such an understanding “would render the claims invalid as
indefinite and for lack of enablement.” Id. at 19–20 (citing Ex. 1002 ¶ 113).
Petitioner further argues that “[e]ach video frame, or picture, in a data
stream is either a frame picture or a field picture,” and it would not be
possible to perform motion estimation in the prediction modes “for field
pictures” from a “frame picture,” and vice versa. Id. at 21–22 (citing Ex.
1002 ¶ 116; Ex. 1019 §§ 6.1.1.1, 6.1.1.4.1–6.1.1.4.2). Lastly, Petitioner
points out that no embodiment is disclosed that concurrently determines
motion estimation in each of the six different possible prediction modes
specified by the MPEG-2 standard, nor does the Specification provide “any
explanation or solution . . . to how this could be accomplished.” Id. at 22
(citing Ex. 1001, 4:22–26; Ex. 1002 ¶ 118).
We adopt Petitioner’s proposed claim interpretations of claims 7 and
12, as discussed above. This comports with our understanding of the
recitation from claim 1 that “concurrently performing motion estimation for
each of a plurality of different prediction modes” does not require that every
possible prediction mode must be evaluated during the motion estimation; if
the plurality of prediction modes is limited, than just that limited number are
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concurrently evaluated. Similarly, we agree with Petitioner that one of
ordinary skill in the art would have viewed the delineation of the prediction
modes by type, i.e., a “frame picture” or a “field picture,” as requiring the
concurrent evaluation of the prediction modes according to the picture type,
per claims 7 and 12. Thus, we are persuaded by Petitioner that claims 7 and
12 merely require that motion estimation is performed for each of the
prediction modes of a selected type concurrently. Patent Owner does not
argue or otherwise refute this interpretation. See PO Resp.; PO Sur-reply.
We determine that this construction is consistent with portions of the
Specification cited, and adopt it for purposes of this decision.
3. “optimum”
Independent claim 1 recites, in part, that the method “determine[s]
which of the prediction modes is an optimum prediction mode,” with
independent claims 39 and 41 similarly reciting the selection of “the
prediction mode that produce[s]/[d] [the]/[an] optimum result.” Petitioner
asserts that these claim limitations would have been understood as
determining a prediction mode that is “best or most suitable.” Pet. 23 (citing
Ex. 1002 ¶¶ 120–124). Petitioner asserts that this would have been in
keeping with the understanding of skilled artisans and the Specification
confirms this understanding of “optimum.” Id. at 23–24 (citing Ex. 1001,
1:12–17, 2:58–3:13, 14:47–54; Ex. 1002 ¶¶ 121–122; Ex. 1009, 154; Ex.
1010, 14–15; Ex. 1005 ¶¶ 22–23; Ex. 1017, 13). Petitioner also contrasts the
construction proffered by Unified Patents, Inc. in its petition, noting that the
“optimum” result “need not be limited to a prediction mode yielding the
smallest value of an error metric—for example, because a POSA would have
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understood that an optimum could be determined based on multiple
metrics.” Id. at 24 (citing Ex. 1002 ¶¶ 125–126; Ex. 1022, 26).
Patent Owner does not argue or otherwise refute this interpretation.
See PO Resp.; PO Sur-reply. We adopt Petitioner’s proposed claim
construction of “optimum,” as we determine that the construction is
consistent with the Specification and the understanding of one of ordinary
skill in the art, as discussed above.
4. “a best match”
Independent claim 1 recites, in part, “determining which of the second
pixel arrays constitutes a best match with respect to the first pixel array for
the optimum prediction mode.” Petitioner asserts that “a best match” would
have been understood as “the second pixel array within a specified search
range of the reference picture having the smallest value of an error metric.”
Pet. 24 (citing Ex. 1002 ¶¶ 127–130). Petitioner further asserts that one of
ordinary skill in the art would have understood the cited portion of claim 1
as referring “to the well-known technique of block matching which is used
for all MPEG-2 prediction modes,” and the “best match” would have been
understood as having the smallest value of an error metric. Id. at 24–25
(citing Ex. 1002 ¶ 128). Petitioner also contrasts the construction proffered
by Unified Patents, Inc., in its petition in IPR2019-01126, asserting that
Petitioner’s “proposed construction clarifies the meaning of the phrase ‘a
best match’ within the context of the claim with proper antecedent basis—
i.e., such that if inserted in place of the phrase ‘a best match,’ the claim
would be grammatically correct.” Id. at 25 (citing Ex. 1002 ¶¶ 131–132; Ex.
1022, 27).
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Patent Owner does not argue or otherwise refute this interpretation.
See PO Resp.; PO Sur-reply. We adopt Petitioner’s proposed claim
construction of “a best match,” as we determine that the construction is
consistent with the Specification and the understanding of one of ordinary
skill in the art, as discussed above.
In light of the parties’ arguments and evidence, we find that it is
unnecessary to construe any additional claim terms expressly for purposes of
this decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor
Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting Vivid Techs., Inc. v. Am.
Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)).
D. Scope and Content of the Prior Art
Petitioner relies on Ishihara, Ishihara798, Ishihara486, and
Bellifemine to show the unpatentability of the Challenged Claims. Pet. 26–
86. We summarize Ishihara briefly below, and, based on our analysis, we
find it unnecessary to summarize Ishihara798, Ishihara486, and Bellifemine.
1. Overview of Ishihara (Ex. 1006)
Ishihara is directed to a processor for encoding in accordance with the
MPEG-2 video compression standard. Ex. 1006, 1502. Ishihara indicates
that it supports all prediction modes in MPEG-2 and estimates three vectors
concurrently. Id. at Abs. A block diagram of the hardware disclosed in
Ishihara is shown in Figure 5 and is reproduced below:
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Fig. 5 of Ishihara illustrates a block diagram of motion estimation processor
In Ishihara, the “Integer-pel Unit (IU)” performs “full search block
matching” and “realizes a better efficiency for finding the optimum [motion]
vectors than the hierarchical search which has been employed in some other
processors.” Id. at 1504. Thereafter, the system performs a half-pixel
precision search to refine the result. Id. IU “consists of 256 processing
elements (PE’s), summation circuits and a minimum-value detector,” with
each PE corresponding to a pixel on the template block. Id. at 1504, Fig. 6.
Each PE compares pixel data from the template block and a search window,
representing pixel data from a reference frame, and computes the absolute
difference between the two. Id. The error information is passed into the
summation circuit that sums the errors together, which outputs the results to
a minimum value detector that keeps track of the vectors that minimize
overall error and selects the best vectors for each template block. Id. at
1505. Ishihara also discloses that “[t]he absolute differences computed in
each PE are classified in four groups[:] upper-top, upper-bottom, lower-top
and lower-bottom.” Id. at 1504, Fig. 8. As shown in TABLE II, reproduced
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below, the summation circuit will sum together errors for different subsets of
pixels and simultaneously calculate the mean absolute difference for
different prediction modes. Id.

TABLE II of Ishihara provides the distortion summation scheme for three
vectors for different picture structures.
E. Anticipation by Ishihara
Petitioner asserts that claims 1−16 and 39−42 are anticipated by
Ishihara under 35 U.S.C. § 102. Pet. 26–63. Patent Owner argues that
Ishihara fails to disclose all elements of the independent claims, where
Ishihara is relied upon to teach those elements. PO Resp. 12−23. For the
reasons provided below, we determine that Petitioner has proved by a
preponderance of the evidence that claims 1−16 and 39−42 are anticipated
by Ishihara.
1. Analysis of Cited Art as Applied to Independent Claim 1
a) Preamble
Petitioner asserts that the preamble of independent claim 1 is taught
by Ishihara. Pet. 31. Petitioner points out that Ishihara is directed to MPEG-
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2 motion estimation that involves coding and compression. Id. (citing Ex.
1004, Abs., 1502−1503, 1508, Fig. 1). Petitioner also asserts that a person
of ordinary skill in the art would have understood Ishihara’s disclosure as
involving real time MPEG-2 motion coding of an NTSC or PAL video
stream, would have understood this to be a disclosure of motion coding an
uncompressed digital video data stream and, even if not expressly disclosed,
would have understood such motion coding to have been inherently
disclosed by Ishihara. Id. (citing Ex. 1002 ¶¶ 171–172).
Patent Owner does not challenge this aspect of Petitioner’s analysis.
See generally PO Resp.; PO Sur-reply. We determine that Petitioner has
demonstrated that the preamble of claim 1 is disclosed by Ishihara.
b) Element [1A]
With respect to this element, Petitioner asserts that Ishihara discloses
a “block matching” technique that compares a pixel array of a picture being
encoded to a plurality of second pixel arrays in a reference picture. Pet.
31−33 (citing Ex. 1006, 1503, Figs. 2, 4). Petitioner also asserts that a
person of ordinary skill in the art would have understood “the well-known
concept of block matching,” in the context of Ishihara, and that the ’005
Patent Specification concedes that such comparisons occur in the prior art
processes. Id. at 31−32 (quoting Ex. 1002 ¶ 173; citing Ex. 1002 ¶¶ 51−54,
173; Ex. 1001, 2:49−54).
Patent Owner does not challenge this aspect of Petitioner’s analysis.
See generally PO Resp.; PO Sur-reply. We determine that that Petitioner
has demonstrated that element [1A] of claim 1 is taught by Ishihara.
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c) Element [1B]
With respect to this element, Petitioner asserts that Ishihara discloses
this element. Pet. 33−37 (citing Ex. 1002 ¶¶ 175−182). Petitioner asserts
that Ishihara explains that its disclosed motion estimation processor
“supports all prediction modes in MPEG[-]2 including frame, field and dual-
prime prediction, and estimates three vectors concurrently,” and that Ishihara
discloses that the chip has a “capability to estimate motion vectors
concurrently for various prediction modes Id. at 33–34 (citing Ex. 1006,
Abs., 1503) (emphasis omitted); see also Ex. 1006, 1504 (“[w]ith this
structure, the processing of block matching and the data transfer are
performed simultaneously”); id. at 1504−05 (“Three different distortions for
three vectors are summed up concurrently under a data flow control in the
summation circuit. Fig. 8 shows the summation circuits, and Table II
summarizes the summation scheme which estimates the three vectors
concurrently for the field and the frame structure pictures.”). Petitioner also
relies on the testimony of Dr. Storer, explaining that “Ishihara discloses
concurrent motion estimation using the same technique to concurrently
perform motion estimation in the same prediction modes described in the
Specification of the ’005 Patent.” Pet. 35 (citing Ex. 1002 ¶ 179) (emphasis
omitted).
Petitioner further asserts that the output of the summation circuit goes
to a minimum-value detector which finds the minimum distortions and
selects the best vectors for each template block. Id. at 36 (citing Ex. 1006,
1503, 1505). Lastly, Petitioner asserts that the determination of a best
prediction mode based on a minimum distortion is equivalent to determining
an optimum prediction mode. Id. at 36−37 (citing Ex. 1002 ¶¶ 181−182).
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Patent Owner contends that Ishihara does not disclose concurrently
performing motion estimation to “determine which of the prediction modes
is an optimum prediction mode.” PO Resp. 13−14; PO Sur-Reply 4
(emphasis omitted). Patent Owner acknowledges that Ishihara discloses that
the best prediction mode is selected from the three prediction modes, but
argues that “there is no disclosure that the determination of the best
prediction mode is based upon comparison of pixels in first- and second-
pixel arrays.” PO Resp. 14−15. But the claim does not require that. As
pointed out by Petitioner, the comparison of pixel arrays is made in step
[1A] of claim 1, and is not disputed by Patent Owner as being disclosed in
Ishihara. Pet. Reply 3−4; see Section II.E.1.b. As discussed above,
Petitioner has shown the comparison of pixel arrays in Ishihara is to
determine an error metric, which is used to determine the optimum
prediction mode. Id. at 4−7 (citing Ex. 1006, 1503, 1505, Figs. 2, 6); see
also Section II.E.1.b (discussing Ishihara’s block matching technique); prior
paragraph (discussing minimum distortion). Although Ishihara discloses the
determination of the best prediction mode and motion vectors for a
macroblock at the same time, the determination is made based on the error
metric coming from the pixel array comparison process. As such, we do not
agree with Patent Owner’s argument that determining the best prediction
mode in Ishihara is not based on a comparison of pixel arrays.
Patent Owner also argues that there is no disclosure in Ishihara that
explains how the best prediction mode is used in the motion process
discussed therein. PO Resp. 15. Patent Owner further asserts that testimony
of Dr. Storer, Petitioner’s declarant, linking the determinations of the best
prediction mode and best vector, is entitled to “little to no weight” because it
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is unsupported by the disclosure of Ishihara itself. Id. Such an assertion is
unavailing because the actual testimony of Dr. Storer is supported by
additional documentation of the selection of the best mode based on a
comparison of prediction errors, as explained by Petitioner. Pet. Reply
10−11 (citing Ex. 1002 ¶¶ 65, 122−134; Ex. 1009, 154). Additionally, even
if, as Patent Owner contends, Ishihara does not explain how the best
prediction mode is explicitly used in the motion process, it is not necessarily
pertinent to element [1B] of claim 1, which only requires a determination of
“which of the prediction modes is an optimum prediction mode,” as Patent
Owner has acknowledged. PO Resp. 14. As such, we do not agree with
Patent Owner’s argument.
We determine that Petitioner has demonstrated that element [1B] of
claim 1 is taught by Ishihara.
d) Elements [1C] and [1D]
Petitioner asserts that Ishihara discloses elements [1C] and [1D] of
claim 1. Pet. 37−41 (citing Ex. 1002 ¶¶ 183−191). Petitioner asserts that a
person of ordinary skill in the art would have understood that Ishihara
teaches an MPEG-2 motion estimation processor that supports all prediction
modes for MPEG-2, and that such encoders determine a best match for all
prediction modes. Id. at 37 (citing Ex. 1002 ¶¶ 183−187). Petitioner also
points to Ishihara as disclosing that “[m]otion estimation is a procedure to
find the best motion vector representing a displacement to the predictor from
the position of the template block.” Id. at 38 (quoting Ex. 1006, 1503; citing
Ex. 1006, 1503−1504, Figs. 6, 8) (emphasis omitted). Petitioner also asserts
that after Ishihara’s ME2 processor determines the “best” vector, Ishihara
discloses that a single motion vector (MV) output is generated from the
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minimum-value detector. Id. at 38−39 (citing Ex. 1006, 1505, Fig. 6; Ex.
1002 ¶ 184). Petitioner also asserts that “[t]o the extent it is argued that the
claims should be construed to require the new creation of a motion vector
after it is determined which prediction mode is optimum, Ishihara discloses
this too.” Id. at 39 (citing Ex. 1002 ¶ 190) (footnote omitted).
Patent Owner argues that the method of claim 1 “requires the
additional step of determining which of the second pixel arrays comprises a
best match for the optimum prediction mode, which was determined in the
previous step.” PO Resp. 16; PO Sur-Reply 6 (emphasis omitted). Patent
Owner asserts that Ishihara teaches determining and comparing the vectors,
and only once mentions a best prediction mode, without any discussion as to
how the best prediction mode is applied to the processing. PO Resp. 17.
Patent Owner further asserts that claim 1 requires the identification of the
“best match based upon a previously determined optimum prediction mode.”
Id. at 18.
Petitioner responds that element [1B] does not recite determining
which of the prediction modes is the optimum prediction mode prior to
performing the step of element [1C]. Pet. Reply 14. Petitioner continues
that Patent Owner “seeks to impose an additional requirement—not present
in the claims and inconsistent with the specification—that the optimum
prediction mode be determined prior to determining a best match.” Id.
Petitioner further argues that “the ‘005 Patent describes determining a best
match and associated error metrics for each prediction mode before
determining which prediction mode is optimal, and then based on the error
metrics accompanying each best match, determines the optimum prediction
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mode.” Id. at 16−17 (citing Pet. 37; Ex. 1001, 8:2−34, 9:27−32, Fig. 3; Ex.
1002 ¶¶ 87−88)(emphasis in original).
As discussed above, element [1B] recites, in part, motion estimation
occurs “in order to determine which of the prediction modes is an optimum
prediction mode.” That recitation does not provide that the optimum
prediction mode is “set” or specified, in that aspect of the claim, as Patent
Owner appears to allege. The recitation of “in order to determine” in that
element dictates a purpose for that motion estimation, i.e., what the motion
estimations can be used to show, but does not explicitly state that the
optimum prediction mode is determined in that step. In other words, a
system that concurrently performs motion estimation for each of a set of
different prediction modes, and which allows for, but does not indicate an
optimum prediction mode at that time, would fall with the scope of that
claim element.
In contrast, in element [1C], “a best match” is specifically determined
“for the optimum prediction mode.” In that step, the optimum prediction
mode must be known at some point in order that the proper determination of
“a best match” be made. We find nothing in claim 1, or in the supporting
Specification, that would prevent the optimum prediction mode
determination from being made during that same step as the “best match”
determination in element [1C]. As Petitioner has argued, the embodiments
described in the ’005 Patent all disclose determining multiple best matches,
and then determining the “optimum prediction mode,” as discussed above.
We find this disclosure does not conflict with Patent Owner’s
characterization of the different embodiments as disclosing the best match
results, the best match being produced by the selected “optimum prediction
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mode.” In each, multiple results of the motion estimation of the pixel arrays
would be determined, and a best match would be determined on the basis of
those results, given the different prediction modes for those results.
As such, we determine that Petitioner has demonstrated that element
[1C] of claim 1 is taught by Ishihara.
With respect to element [1D] of claim 1, Patent Owner argues that the
element requires the generating of a motion vector in response to the
determining step, and, in contrast, Ishihara teaches a system in which the
vectors are generated and compared to determine a best vector, but such a
vector would not be generated in response to a determining step. PO Resp.
19−20; PO Sur-Reply 8. Patent Owner also argues that selecting an existing
vector does not “constitute[] ‘generating’ a vector,” and is not supported by
the record. PO Resp. 21; PO Sur-Reply 8−9. Patent Owner argues that
mere selection of a preexisting vector as being equivalent to the “generating
a motion vector” would render the language of claim 1, namely “in response
to,” as having no meaning. Id.
Petitioner responds that the Specification of the ’005 Patent makes
clear that “determining which prediction mode is optimum is done based on
calculating motion vectors for each mode” and, thus, “motion vectors thus
necessarily must be generated before determination of optimum prediction
mode is made.” Pet. Reply 21 (citing Ex. 1002 ¶¶ 188−189; Ex. 1001,
4:59−61). Petitioner also cites to the testimony of Dr. Storer providing that
a person of ordinary skill in the art “would have understood that ‘generating
a motion vector’ or ‘generating one or more motion vectors’ can include
selecting one or more motion vectors that has previously been calculated as
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part of the search operation.” Id. at 21−22 (quoting Ex. 1002 ¶ 189). We
agree with Petitioner.
As we noted in the Institution Decision (Inst. Dec. 29), Petitioner
relies upon testimony from Dr. Storer, quoted above. We have no
contravening testimony on this point. We are also persuaded that the
language of element [1D], namely “in response to the determining step,” acts
to set when the generating occurs in the context of the claim, i.e., after the
prior step, instead of requiring a recalculation of a motion vector. Further,
we agree with Petitioner that the embodiments disclosed in the ’005 Patent
also make clear that the process discussed there indicates that motion vectors
are generated before the best match or optimum prediction mode is
determined. As such, we determine, based on the preponderance of
evidence before us, that Ishihara’s disclosure that its ME2 processor
determines the “best” vector and that a single motion vector (MV) output is
generated from the minimum-value detector, meets the limitations of
element [1D] of claim 1.
Both parties also discuss the “half-pel” processing that is disclosed in
Ishihara as also meeting the limitation of element [1D]. Pet. 39−41; PO
Resp. 21−23; Pet. Reply 23−24; PO Sur-reply 9. As per our discussion
above, however, we agree with the Petitioner’s understanding of the scope of
element [1D] and we need not reach the additional disclosure of Ishihara
with respect to this element. We determine that Petitioner has demonstrated
that element [1D] of claim 1 is taught by Ishihara. As such, we determine
that Petitioner has demonstrated that elements [1C] and [1D] of claim 1 are
disclosed by Ishihara.
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Based on the evidence in this record, we are persuaded that Petitioner
has shown by a preponderance of the evidence that Ishihara teaches all of the
limitations of independent claim 1 and renders that claim anticipated under
35 U.S.C. § 102, for the reasons identified in the Petition, as discussed
above.
2. Analysis of Cited Art as Applied to Independent Claims 39 and 41
With respect to the limitations of independent claim 39, Petitioner
relies on the citations and arguments made with respect to the preamble and
element [1B] of claim 1. Pet. 58−60 (citing Pet. 31, 33−37; Ex. 1002
¶¶ 232−236). Similarly, with respect to the limitations of independent claim
41, Petitioner relies on the citations and arguments made with respect to the
preamble and elements [1B], [1C], and [1D] of claim 1. Pet. 60−62 (citing
Pet. 31−41; Ex. 1002 ¶¶ 239−244).
Patent Owner states that with respect to independent claims 39 and 41,
“the Petition relies on the same discussion as [the Petition’s] challenge to
independent claim 1,” emphasizing the alleged deficiencies of this ground
with respect to elements of independent claim 1, discussed above. See PO
Resp. 12. We do not find Patent Owner’s arguments persuasive, per our
discussion of independent claim 1 above. Based on the evidence in this
record, we are persuaded that Petitioner has shown by a preponderance of
the evidence that Ishihara teaches all of the limitations of claims 39 and 41
under 35 U.S.C. § 102, for the reasons identified in the Petition, as discussed
above.
3. Analysis of Cited Art as Applied to Dependent Claims 2−16, 40,
and 42
With respect to dependent claims 2−5, 40, and 42, Petitioner asserts
that Ishihara discloses the particulars required by the MPEG standard. Pet.
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41−43, 60, 63. Petitioner identifies that Ishihara describes a “MPEG-2
motion estimation processor,” and supports all prediction modes in MPEG-
2. Id. (citing Ex. 1006, Abs., 1502, TABLE I, Fig. 3; Ex. 1002 ¶¶ 192−199,
237−238, 245−246).
Claim 6 details providing information identifying a picture type; claim
7 lists different prediction modes for those picture types; and claims 8−12
recite different sub-sets of prediction modes. Petitioner asserts that Ishihara
either expressly or inherently discloses the limitations of these claims. Pet.
44−58 (citing Ex. 1006, Abs., 1504−1505, 1507−1508, TABLE I, Fig. 8; Ex.
1002 ¶¶ 200−229). Petitioner asserts that Ishihara explains that the
comparison of the first pixel array to second pixel arrays can be done
according to different modes: one for field pictures and one for frame
pictures, and relies on Dr. Storer’s testimony that “the method of Ishihara
must necessarily involve identifying the picture type for use in the
comparison step because operation changes depending on what picture type
is being encoded.” Id. at 44−45 (quoting Ex. 1002 ¶ 202).
Claims 13−16 recite devices that implement different methods recited
in specific claims. Petitioner asserts that Ishihara discloses a “MPEG2
motion estimation processor,” which can perform the different methods
claims, as discussed above. Pet. 58 (citing Ex. 1006, 1502, Fig. 14; Ex.
1003 ¶¶ 230−231).
Patent Owner does not challenge Petitioner’s analysis of the
dependent claims other than arguing alleged deficiencies of this ground with
respect to elements of independent claim 1, discussed above. See PO Resp.
26.
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Based on the evidence in this record, we are persuaded that Petitioner
has shown by a preponderance of the evidence that Ishihara teaches all of the
limitations of claims 2−16, 40, and 42 under 35 U.S.C. § 102, for the reasons
identified in the Petition, as discussed above.
4. Conclusion on Anticipation by Ishihara
For the reasons provided above, we determine that Petitioner has
shown by a preponderance of the evidence that Ishihara renders 1−16 and
39−42 of the ’005 Patent unpatentable under 35 U.S.C. § 102.
F. Obviousness over Ishihara in Combinations with Ishihara798,
Ishihara486, and Bellifemine
Petitioner asserts that claims 1−16 and 39−42 would have been
rendered obvious by Ishihara in combination with Ishihara798, Ishihara in
combination with Ishihara486, and Ishihara in combination with Bellifemine
under § 103. Pet. 63–86. We briefly discuss these additional grounds
below.
With respect to Ishihara798, Petitioner asserts that one of ordinary
skill in the art would have been motivated to combine Ishihara798 with
Ishihara “because they name common authors, share common objectives
(directed to providing improvements to motion estimation devices/methods
without increasing computational cost and complexity), and are generally
directed to the same subject matter (performing motion estimation in a
plurality of prediction modes in parallel).” Pet. 63. Petitioner incorporates
by reference much of the analysis from the anticipation ground and asserts
that Ishihara798 discloses concurrently performing motion estimations for a
plurality of different prediction modes and determines the optimum
prediction mode. Id. at 64−65 (citing Ex. 1011, Abs., 20:60−64, 24:29−33,
Fig. 148). Petitioner also asserts that one of ordinary skill in the art would
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have had a reasonable expectation of success in making such a modification
“because such a modification comprises using a known technique
(comparing error evaluation function values to select the optimum prediction
mode, as explained by Ishihara798) to improve a similar device (the ME2
circuit described by Ishihara) to yield a predictable result (selecting an
optimal prediction mode)”. Id. at 69 (citing Ex. 1002 ¶¶ 266, 255−258).
With respect to the proffered combinations of Ishihara with
Ishihara486 and Ishihara with Bellifemine, Petitioner provides similar
arguments and rationales supporting the combinations of references and
similar reliance on the anticipation ground over Ishihara alone. Compare
Pet. 63−72, with Pet. 72−78, with Pet. 79−86. As such, we are persuaded
and find that Petitioner has demonstrated a sufficient rationale for the
combinations of Ishihara and Ishihara798, Ishihara and Ishihara486, and
Ishihara and Bellifemine.
Patent Owner contends that “[t]he Petition fails to explain why the
cited teachings from Ishihara ’798 or Ishihara ’486 would cause the
‘modified’ system of Ishihara to perform any differently than as discussed
above for the Ishihara anticipation grounds, and these challenges are
deficient for the same reasons.” PO Resp. 24. Patent Owner also contends
that Bellifemine is silent with respect to “concurrently” performing
operations. Id. As such, Patent Owner asserts that none of the additionally
cited references cure the deficiencies of Ishihara, and the additional grounds
do not show the obviousness of the Challenged Claims. Id. at 24−26; PO
Sur-reply 9−11. Petitioner responds that Patent Owner’s “arguments are
completely without merit, unsupported by any evidence, and should be
afforded no weight.” Pet. Reply 28.
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Based on the evidence in this record, and discussed above, Petitioner
has demonstrated that there is no “deficiency” in Ishihara with respect to any
challenged claim. The combination of Ishihara with other references only
strengthens our conclusion that the Challenged Claims would have been
obvious. We are persuaded that Petitioner has shown by a preponderance of
the evidence that the combinations of Ishihara and Ishihara798, Ishihara and
Ishihara486, and Ishihara and Bellifemine teach all of the limitations of
claim 1−16 and 39−42. The combined teachings of the references in each
alleged ground of obviousness would have rendered claims 1–16 and 39–42
obvious under 35 U.S.C. § 103, for the reasons identified in the Petition, as
discussed above.
G. Constitutional Argument
Patent Owner also argues that Administrative Patent Judges (“APJs”)
“are principal officers under the Appointments Clause of the Constitution”
“but undisputably are not appointed through the constitutionally-mandated
mechanism of appointment for principal officers.” PO Resp. 26−30. The
Federal Circuit, however, addressed this issue and devised a remedy in
Arthrex, Inc. v. Smith & Nephew, Inc., 941 F.3d 1320, 1325 (Fed. Cir. 2019).
Patent Owner argues that the remedy devised by Federal Circuit
“impermissibly re-writes the statutes governing APJs.” Id. at 27. We
decline to consider the argument because the Arthrex decision states
otherwise. See Arthrex, 941 F.3d at 1337 (“This as-applied severance . . .
cures the constitutional violation.”).

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III. CONCLUSION
Our final determination in this case is summarized below:

IV. ORDER
In consideration of the foregoing, it is hereby:
ORDERED that claims 1−16 and 39−42 of the ’005 Patent have been
proven to be unpatentable;
FURTHER ORDERED that, because this is a Final Written Decision,
the parties to the proceeding seeking judicial review of the Decision must
comply with the notice and service requirements of 37 C.F.R. § 90.2.

Claims 35 U.S.C. § Reference(s)
Claim(s)
Shown
Unpatentable
Claims
Not shown
Unpatentable
1−16, 39−42 102 Ishihara 1−16, 39−42
1−16, 39−42 103 Ishihara,
Ishihara798
1−16, 39−42
1−16, 39−42 103 Ishihara,
Ishihara486
1−16, 39−42
1−16, 39−42 103 Ishihara,
Bellifemine
1−16, 39−42
Overall
Outcome
1−16, 39−42
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For PETITIONER:

Eliot D. Williams
G. Hopkins Guy III
Ali Dhanani
Michael Knierim
Kurt Pankratz
BAKER BOTTS L.L.P.
eliot.williams@bakerbotts.com
hop.guy@bakerbotts.com
ali.dhanani@bakerbotts.com
michael.knierim@bakerbotts.com
kurt.pankratz@bakerbotts.com

For PATENT OWNER:

Jeffrey A. Stephens
Ryan Loveless
Brett Mangrum
James Etheridge
Jeffrey Huang
ETHERIDGE LAW GROUP
jstephens@etheridgelaw.com
ryan@etheridgelaw.com
brett@etheridgelaw.com
jim@etheridgelaw.com
jeff@etheridgelaw.com