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. IPR2013-00327
`
`__________________________________________________________________
`
`
`
`
`
`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. IPR2013-00327
`
`__________________________________________________________________
`
`
`
`
`
`Petition for Inter Partes Review
`of U.S. Pat. No. 7,477,284
`IPR2013‐00219
`EXHIBIT
`Sony‐
`
`
`
`No. IPR2013-00327
`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
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`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
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`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
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`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-
`
`1115.
`
`5. I submit this declaration in support of the Petition for Inter Partes Review of
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`U.S. Pat. No. 7,477,284, No. IPR2013-00327. I have previously submitted a
`
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`2
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`declaration in support of the Petition for Inter Partes Review of U.S. Pat. No.
`
`7,477,284, No. IPR2013-00219.
`
`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
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`disclosed by the ’284 Patent would have at least a Master of Science degree in
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`Electrical Engineering, Computer Engineering, or Computer Science as well as
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`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”);
`
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`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. U.S. Pat. No. 5,737,491 (“Allen”);
`
`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
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`video imager described in Kawakita records frames of 320x240 pixels.
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`Kawakita also describes digital processing steps including “template
`
`matching” and receiving “detection results” as part of the procedure for
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`determining slit widths. It would have been necessary and obvious to
`
`employ a processor to perform these steps, especially in light of the
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`number of pixels being processed, which would be unfeasible to
`
`perform by hand.
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`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 the “Field Test” section of
`
`Kawakita would understand Kawakita to report that stereoscopic
`
`panoramic mosaic images generated using the technique described in the
`
`paper were displayed and that “the sense of depth was faithfully
`
`reproduced.” Even if the report of stereoscopic viewing of the
`
`panoramic mosaic images were not included in Kawakita, a person
`
`ordinary skill in the art reading the remainder of Kawakita would
`
`understand that stereoscopic display of the panoramic mosaic images to
`
`be disclosed or, at least, obvious. Indeed, section 6 of Kawakita, entitled
`
`“Stereoscopic Viewing Using Depth Parallax Angle” describes
`
`adjustments to the relative positions of the panoramic mosaic images in
`
`order to display them for stereoscopic viewing.
`
`e. A person of ordinary skill in the art reading Kawakita would understand
`
`that it would be preferable to miniaturize the image generation
`
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`components disclosed by Kawakita so that they would all fit within a
`
`single housing including the imager, processor, and display.
`
`11. With respect to Ishiguro:
`
`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.
`
`12. With respect to Kawakita and Chen:
`
`a. Both Kawakita and Chen are directed towards image processing systems
`
`which generate stereoscopic images of a scene to provide a sense of
`
`depth.
`
`b. A person of ordinary skill in the art developing the imaging technology
`
`described by Kawakita, would be motivated to include a processor, such
`
`as described by Chen, to divide segments from the captured images of a
`
`scene and generate mosaics. Further, as stated in ¶ 10.b,c, such a
`
`processor would have been obvious and necessary.
`
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`6
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`c. Similarly, a person of ordinary skill in the art developing the imaging
`
`technology described by Kawakita, would be motivated by the
`
`disclosures of both Kawakita (see ¶ 10.d.) and Chen to include a stereo
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`image display for displaying the mosaics to provide a sense of depth.
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`d. A person of ordinary skill in the art reading Kawakita would also
`
`understand that Kawakita discloses an experimental arrangement for
`
`laboratory use and that order to implement Kawakita’s arrangement as a
`
`transportable unit for field use or as a commercial product, it would be
`
`necessary and normal to miniaturize and package the image generation
`
`components disclosed by Kawakita so that they would all fit within a
`
`single housing including the imager, processor, and display.
`
`13. With respect to Chen and Allen:
`
`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.
`
`b. Accordingly, a person of ordinary skill in the art would have been
`
`motivated to combine the teachings of Chen with Allen to include a
`
`communications apparatus, such as the wireless transceiver described by
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`Allen, into the camera described by Chen, in order to transmit the
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`generated images to a computer or other device.
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`c. Allen’s disclosure of a wireless transceiver to transmit image data from a
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`camera is one known solution to the obvious need for some means for
`
`transferring image data from a digital camera to enable display of images
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`on other devices, or printing of images, or off-camera storage, or and
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`other uses of the image data.
`
`d. Indeed, a person of ordinary skill, just employing common sense, would
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`find it apparent that an imaging apparatus from which the image data
`
`could not be removed would have limited utility, and that it would be
`
`advantageous, if not essential, to have some means to get image data off
`
`the imaging apparatus.
`
`14. With respect to Ishiguro and Chen:
`
`a. Both Ishiguro and Chen are directed towards image processing systems
`
`which generate stereoscopic images of a scene to provide a sense of
`
`depth.
`
`b. A person of ordinary skill in the art familiar with Ishiguro’s image
`
`capturing and processing system would look to Chen’s teaching of a
`
`stereo image display for displaying the mosaics to provide a sense of
`
`depth.
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`8
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`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`c. 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
`
`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. A person of
`
`ordinary skill in the art familiar with the system disclosed by Ishiguro
`
`would look to Chen’s teaching of enclosing the imager, processor,
`
`display, and all other components of the camera system in the same
`
`housing, as was well known in camera design, to produce the predictable
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`result of making the imaging apparatus disclosed in Ishiguro more
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`compact and user friendly.
`
`15. 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-
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`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
`
`
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`9
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`
`
`JUN-27-2013 16:11
`06/27/2013 12:27 FAX
`
`KENYON & KENYON
`
`212 425 5288
`
`P.003/003
`1410003/0003
`
`No. IPR2013-00327
`Expert Declaration of Trevor Darrell
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`display the stereoscopic images disclosed in Ishig~u:o using the anaglyphs
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`disclosed by Berger.
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`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated June::? ? 2013
`
`Trevor Darrell
`
`10
`
`TOTAL P.003
`
`
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