UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________________________________________
`
`SONY CORPORATION
`Petitioner
`
`Patent No. 7,477,284
`Issue Date: Jan. 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
`__________________________________________________________________
`
`EXPERT DECLARATION OF TREVOR DARRELL
`
`No. IPR2013-00219
`
`__________________________________________________________________
`
`
`
`
`
`Petition for Inter Partes Review
`of U.S. Pat. No. 7,477,284
`IPR2013‐00219
`EXHIBIT
`Sony‐
`
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________________________________________
`
`SONY CORPORATION
`Petitioner
`
`Patent No. 7,477,284
`Issue Date: Jan. 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
`__________________________________________________________________
`
`EXPERT DECLARATION OF TREVOR DARRELL
`
`No. IPR2013-00219
`
`__________________________________________________________________
`
`
`
`
`
`Petition for Inter Partes Review
`of U.S. Pat. No. 7,477,284
`IPR2013‐00219
`EXHIBIT
`Sony‐
`
`
`
`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
`I, Trevor Darrell, do hereby make the following declaration:
`
`1. I am a Professor in Residence at the University of California, Berkeley in the
`
`department of Electrical Engineering and Computer Sciences, College of
`
`Engineering and have served in that capacity since 2011.
`
`2. I am also the head of the Computer Vision Group at the International
`
`Computer Science Institute (a research organization affiliated with Berkley) and
`
`have served in that capacity since 2008.
`
`3. I received my B.S.E. degree in Computer Science and Engineering from the
`
`University of Pennsylvania in 1988, received a M.S. degree from the Media Lab
`
`at the Massachusetts Institute of Technology (“MIT”) in 1991 and received a
`
`Ph.D. from MIT in 1996.
`
`4. I am an author of nearly two hundred publications in peer reviewed journals
`
`and conferences in computer vision and related fields. At Berkeley, I teach
`
`graduate level courses including CS 280 Computer Vision and CS 294 Object
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`Activity Recognition Seminar. I have also given numerous lectures and
`
`attended many conferences on computer vision and related fields. A list of my
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`publications and invited lectures can be found in the attached CV. See Sony-
`
`1013.
`
`5. I submit this declaration in support of the Petition for Inter Partes Review of
`
`U.S. Pat. No. 7,477,284, No. IPR2013-00219.
`
`
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`2
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`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
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`6. I have reviewed U.S. Pat. No. 7,477,284 (the “’284 Patent”) as well as U.S. Pat.
`
`No. 6,665,003 (the “’003 Patent”), which is incorporated into the ’284 Patent
`
`by reference.
`
`7. Based upon my experience and education, I consider myself to be a person of
`
`at least ordinary skill in the field of technology disclosed by the ’284 Patent,
`
`including the generation and display of stereoscopic images as well as
`
`stereoscopic panoramic images.
`
`8. In 1998, a person with ordinary skill in the art with respect to the technology
`
`disclosed by the ’284 Patent would have at least a Master of Science degree in
`
`Electrical Engineering, Computer Engineering, or Computer Science as well as
`
`two to three years of additional graduate level experience or related industry
`
`experience.
`
`9. In preparing this declaration, I have reviewed the following publications:
`
`a. Certified English Translation of VRSJ Research Report including
`
`Yasuhiro Kawakita, Yoshitaka Hamaguchi, Akitoshi Tsukamoto,
`
`Toshihiko Miyazaki, Generation of Panoramic Stereo Images from Movie Using
`
`Single Video Camera, Kansai Laboratory Research & Development Group,
`
`OKI Electric Industry Co., Ltd. (Nov. 27, 1997) (“Kawakita”);
`
`
`
`3
`
`
`
`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
`
`b. Hiroshi Ishiguro, Masashi Yamamoto, and Saburo Tsuji, Acquiring
`
`Omnidirectional Range Information, SYSTEMS AND COMPUTERS IN JAPAN,
`
`Vol. 23, No. 4, 47-56 (1992) (“Ishiguro”);
`
`c. U.S. Pat. No. 1,422,527 (“Berger”);
`
`d. KODAK DIGITAL SCIENCE(TM) DC50 ZOOM CAMERA USER’S GUIDE
`
`(Jan. 1996) (“Kodak”); and
`
`e. U.S. Pat. Pub. No. 2001/0010546 A1 (“Chen”).
`
`10. With respect to Kawakita:
`
`a. Kawakita discloses a technique to generate stereoscopic panoramic
`
`images by excising slit images from images captured by a rotating camera
`
`and mosaicing the respective slit images together. In Section 1 of the
`
`paper, Kawakita also discusses creating a 2D panoramic image using
`
`center slit images.
`
`b. A person of ordinary skill in the art reading Kawakita would understand
`
`that the processing steps disclosed by Kawakita would necessarily have
`
`been performed by a processor within a computer or workstation. The
`
`video imager described in Kawakita records frames of 320x240 pixels.
`
`Kawakita also describes digital processing steps including “template
`
`matching” and receiving “detection results” as part of the procedure for
`
`determining slit widths. It would have been necessary and obvious to
`
`
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`4
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`
`
`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
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`employ a processor to perform these steps, especially in light of the
`
`number of pixels being processed, which would be unfeasible to
`
`perform by hand.
`
`c. In fact, virtually every imaging project to which I have contributed,
`
`including the nearly 200 listed in my CV, has employed a processor, such
`
`as, for example, within a computer or workstation.
`
`d. A person of ordinary skill in the art reading Kawakita would understand
`
`that it would be preferable to miniaturize the image generation
`
`components disclosed by Kawakita so that they would all fit within a
`
`single housing including the imager, processor, and display.
`
`e. It also would have been obvious to a person of ordinary skill in the art to
`
`combine the 2D panorama and stereoscopic panorama embodiments
`
`discussed in Kawakita by excising a center slit as well as a left and right
`
`slit to obtain both a 2D panoramic image and a stereoscopic panoramic
`
`image pair. One of ordinary skill in the art would understand that setting
`
`the focal point of the camera at a reasonable distance away from the
`
`rotational axis will not materially affect the quality of the center slit 2D
`
`panorama, just as it does not materially affect the quality of the left and
`
`right slit images.
`
`11. With respect to Ishiguro:
`
`
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`5
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`
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`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
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`a. Ishiguro discloses a method for generating a stereoscopic
`
`omnidirectional image pair. Ishiguro also discloses using a single series
`
`of vertical slit images to create a 2D panoramic image.
`
`b. It would have been commonplace, if not necessary, for scientists such as
`
`Ishiguro and his colleagues to stereoscopically view the images generated
`
`by the technique disclosed by Ishiguro on a stereoscopic display in order
`
`to confirm that the mosaic images accurately presents relative depths of
`
`objects in the scene.
`
`c. It would have been obvious to a person of ordinary skill in the art to
`
`combine the embodiments depicted in Fig. 1 and Fig. 4 in Ishiguro by
`
`including a center slit in the Fig. 4 system in order to obtain both a 2D
`
`panoramic image and a stereoscopic panoramic image pair. One of
`
`ordinary skill in the art would understand that setting the focal point of
`
`the camera at a reasonable distance away from the rotational axis will not
`
`materially affect the quality of the center slit 2D panorama, just as it does
`
`not materially affect the quality of the left and right slit images.
`
`d. A person of ordinary skill in the art reading Ishiguro would also
`
`understand that Ishiguro discloses an experimental arrangement for
`
`laboratory use and that order to implement Ishiguro’s arrangement as a
`
`transportable unit for field use or as a commercial product, it would be
`
`
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`6
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`
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`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
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`necessary and normal to miniaturize and package the image generation
`
`components disclosed by Ishiguro so that they would all fit within a
`
`single housing including the imager, processor, and display.
`
`12. With respect to Chen and Kodak:
`
`a. A person of ordinary skill in the art developing imaging technology (such
`
`as the technology disclosed by Chen) for potential consumer market use
`
`would have looked to supplement their technology with user friendly
`
`camera features commonplace in the consumer camera market.
`
`Accordingly, a person of ordinary skill in the art would have been
`
`motivated to combine the teachings of Chen with Kodak.
`
`13. With respect to Ishiguro and Berger:
`
`a. Berger discloses an anaglyph print technology. As Berger states, an
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`anaglyph is a print of two oppositely colored superimposed images,
`
`which, when viewed simultaneously with an anaglyphscope (e.g., red-
`
`cyan glasses), provide a sense of depth. Berger, 1:48-53.
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`b. A person of ordinary skill in the art reading Ishiguro would be aware of
`
`the technology disclosed by Berger and it would have been obvious to
`
`display the stereoscopic images disclosed in Ishiguro using the anaglyphs
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`disclosed by Berger.
`
`
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`7
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`
`
`No. IPR2013-00219
`Expert Declaration of Trevor Darrell
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated March~ 2013
`
`Trevor Darrell
`
`8
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