UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________
`
`ACTIVATION BLIZZARD, INC. and RIOT GAMES, INC.,
`Petitioners
`
`v.
`
`GAME AND TECHNOLOGY CO., LTD.,
`Patent Owner
`_____________
`
`Case IPR2016-01880
`Patent 8,035,649
`
`_____________
`
`PRELIMINARY RESPONSE TO PETITION UNDER 37 C.F.R. § 42.107
`
`
`As permitted under 37 C.F.R. § 42.107, Game and Technology Co., Ltd.
`
`(“Patent Owner”) timely submits this Preliminary Response to Petition Under 37
`
`C.F.R. § 42.107 (“Preliminary Response”). This Preliminary Response sets forth
`
`the reasons why the Petition for Inter Partes Review of U.S. Patent No. 8,035,649
`
`(“Petition”) submitted by Activation Blizzard, Inc. and Riot Games, Inc.
`
`(“Petitioners”) should be denied and dismissed by the Patent Trial and Appeal
`
`Board (“Board”).
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`

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`PRELIMINARY RESPONSE TO PETITION UNDER 37 C.F.R. § 42.107
`Case IPR2016-01880
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`TABLE OF CONTENTS
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`
`
`TABLE OF CONTENTS ............................................................................................ i
`
`EXHIBITS ............................................................................................................... iii
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`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
`
`THE ‘649 PATENT ......................................................................................... 2
`
`III. PRECISE RELIEF REQUESTED .................................................................. 4
`
`IV. Claim Construction .......................................................................................... 5
`
`A.
`
`B.
`
`C.
`
`rendering/rendered ................................................................................. 6
`
`“second image data not being loaded on a buffer” ............................. 14
`
`“in a buffer space including a plurality of buffers, in which the image
`resource data are loaded in rotation on the buffer by frame,
`respectively” ........................................................................................ 16
`
`D. “generating the first image at a first frame rate” and “generating a
`second image … at a second frame rate” ............................................ 19
`
`V. NO LIKELIHOOD THAT CLAIMS 1-3, 7-9, AND 11-16 OF THE ‘649
`ARE OBVIOUS OVER POSE IN VIEW OF BOWEN ............................... 21
`
`A. “second image is generated without being rendered” (claims 1, 13,
`and 15) ................................................................................................. 21
`
`B.
`
`“image resource data of the second image is not loaded in the buffer
`space” (claim 1) and “second image data not being loaded on a buffer”
`(claims 13, 15) ..................................................................................... 24
`
`1.
`
`2.
`
`Claim 1 ................................................................................................ 24
`
`Claims 13 and 15 ................................................................................. 27
`
`C. Combination of “loaded in rotation on the buffer by frame,
`respectively” and “generating the first image at a first frame rate by
`sequentially rendering the loaded image resource data” (claim 1) ..... 29
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`D. “generating the first image at a first frame rate” and “generating a
`second image … at a second frame rate” (claims 1, 13, and 15) ........ 34
`
`E.
`
`“first frame rate is less than the second frame rate” (claims 2, 14, and
`16) ........................................................................................................ 38
`
`F. No Motivation to Combine Pose and Bowen (claims 1-3, 7-9, and 11-
`16) ........................................................................................................ 39
`
`VI. NO LIKELIHOOD THAT CLAIMS 4-6 AND 10 OF THE ‘649 PATENT
`ARE OBVIOUS OVER POSE IN VIEW OF BOWEN, AND FURTHER IN
`VIEW OF RODGERS ................................................................................... 41
`
`VII. CONCLUSION .............................................................................................. 48
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`PATENT OWNER PRELIMINARY RESPONSE TO IPR PETITION
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`EXHIBITS
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`
`
`Exhibit No.
`2001
`
`2002
`
`Document
`Verified English Translation of Priority Document KR 10-2004-
`0049556
`Priority Document KR 10-2004-0049556 from file history
`
`
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`PRELIMINARY RESPONSE TO PETITION UNDER 37 C.F.R. § 42.107
`Case IPR2016-01880
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`I.
`
`INTRODUCTION
`
`Patent Owner respectfully submits that the Petition requesting Inter Partes
`
`Review fails to demonstrate a reasonable likelihood that claims 1- 16 of U.S.
`
`Patent No. 8,035,649 (“the ‘649 Patent”) are unpatentable. This is at least because
`
`the Petition relies on erroneous claim construction and misrepresentations of prior
`
`art references’ disclosures. For example, the Petition fails to establish that:
`
`(1) “the second image data is generated without being rendered” of
`
`independent claims 1, 13, and 15 was disclosed or suggested in the prior art,
`
`(2) “the second image is not loaded in the buffer space” of independent
`
`claims 1, and “second image data not being loaded on a buffer” of independent
`
`claims 13 and 15 were disclosed or suggested in the prior art,
`
`(3) the “loading the identified image resource data in a buffer space … in
`
`which the image resourced data are loaded in rotation” of independent claim 1
`
`was disclosed or suggested by the prior art, and
`
`(4) the “generating the first image at a first frame rate” and “generating a
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`second image … at a second frame rate” of independent claims 1, 13, and 15
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`were disclosed or suggested by the prior art.
`
`Thus, the Petition fails to establish a reasonable likelihood that each and
`
`every element of the challenged claims would have been rendered obvious by the
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`prior art. As a result, Petitioners have not carried their burden of showing that
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`there is a reasonable likelihood that Petitioners would prevail with respect to the
`
`claims challenged in the Petition.
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`II. THE ‘649 PATENT
`
`
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`The ‘649 patent is directed to a method and system for updating images
`
`displayed on a display device, in which a first generated image and a second
`
`generated image are composited, and the composited image is displayed. See ‘649
`
`patent (Ex. 1001) at claims 1, 13, and 15. Image resource data for the first image is
`
`loaded in a buffer space including a plurality of buffers. See ‘649 patent (Ex.
`
`1001) at 5:37-62. The first image is generated at a first frame rate by rendering the
`
`loaded image resource data. See ‘649 patent (Ex. 1001) at 5:63-6:8. “Rendering,”
`
`as discussed in the ‘649 patent, includes various processes that improve the visual
`
`appearance and definition of an image (see ‘649 patent (Ex. 1001) at 9:57-10:28,
`
`emphasis added):
`
`Hereinafter, the rendering used in the present invention will be
`
`schematically described. The rendering is one of methods of
`generating an image. For example, the rendering may be used for
`generating an actual graphic image by realizing a three-dimensional
`texture such as the variance in colors and density.
`
`Real-time rendering means that images are rapidly generated
`
`in computer, which is one of areas in which a mutual action with a
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`user is most active in computer graphics. A speed of displaying an
`image may be measured by frames per second:fps. In case that an
`image is displayed at a speed not less than 15 frames/second as
`described above, it may be called as real-time rendering. On the other
`hand, since users cannot sense a difference in speed when the speed is
`more than 75 frames/second, it is not necessary to aimlessly increase
`an image display speed.
`
`The substantial purpose of real-time rendering is to generate
`
`and display an image at a speed that can improve a visual appearance
`of an object as an image and make a user to sense proper interactivity.
`In this case, various methods may be used. Particularly, the
`interactivity may be embodied by acceleration algorithms.
`
`For example, in the real-time rendering, a method of giving a
`
`definition of a material and light in order to improve the visual
`appearance and improving the definition via anti-aliasing, gamma
`correction, advanced lighting, and shading.
`
`Also, the real-time rendering may use texturing as the
`
`acceleration algorithms. The texturing is performed by a method of
`covering an image on the surface of an object. Culling and pipeline
`optimization method are used as other examples of the acceleration
`algorithms.
`
`Though the rendering is schematically described in the above,
`
`methods capable of being used in rendering are not limited as
`described above. Namely, the screen update system according to the
`present invention may render by using all methods of rendering, such
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`as not only conventional methods of rendering also newly developed
`rendering methods. It is truly said that the described above belongs to
`the scope of the present invention.
`
`
`
`In contrast, image resource data of the second image is not loaded in the
`
`buffer space, and the second image data of the second image is generated at a
`
`second frame rate “without rendering.” See ‘649 patent (Ex. 1001) at 6:38-42 and
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`6:61-67. “Since the second image is generated without being loaded onto the
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`buffer means and there is a small amount of computation required to generate the
`
`second image, the second image may be generated at a higher speed than the first
`
`image. Since the second image does not need to be rendered, or if rendering is
`
`required, the amount of computation is not large, the second image may be real-
`
`time updated at relatively higher frame rate than the first image.” See ‘649 patent
`
`(Ex. 1001) at 7:4-7.
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`III. PRECISE RELIEF REQUESTED
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`The Petition challenges the validity of claims 1-16 based on the following
`
`grounds:
`
` Ground 1: Claims 1-3, 7-9, and 11-16 as allegedly obvious under 35
`
`U.S.C. § 103(a) over Pose et al. (U.S. Patent No. 5,841,439) (Ex.
`
`1023) in view of Bowen et al. (U.S. Patent No. 6,147,695) (Ex. 1024).
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` Ground 2: Claims 4-6 and 10 as allegedly obvious under 35 U.S.C. §
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`103(a) over Pose in view of Bowen, and further in view of Rogers et
`
`al. (U.S. Pub. 2010/0137015) (Ex. 1025).
`
`Patent Owner respectfully requests the Board to deny the Petition for failing
`
`to establish a reasonable likelihood that each and every element of claims 1-16 of
`
`the ‘649 Patent would have been rendered obvious by the cited art.
`
`IV. Claim Construction
`
`A claim subject to Inter Partes Review is given its “broadest reasonable
`
`construction in light of the specification of the patent in which it appears.” 37
`
`C.F.R. § 42.100(b). “The Court of Appeals held that this statute gives the Patent
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`Office the legal authority to issue its broadest reasonable construction regulation.
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`We agree.” Cuozzo Speed Technologies, LLC v. Lee, 136 S.Ct. 2131, 2142 (2016).
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`This means that the words of the claim are given their plain meaning from the
`
`perspective of one of ordinary skill in the art unless that meaning is inconsistent
`
`with the specification. In re Zletz, 893 F.2d 319, 321 (Fed. Cir. 1989). In
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`determining the plain meaning, proper claim construction requires interpretation of
`
`an entire claim in context, not a single element in isolation. Hockerson–
`
`Halberstadt, Inc. v. Converse Inc., 183 F.3d 1369, 1374 (Fed.Cir.1999). When
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`determining how a skilled artisan would have understood a claim term, the Board
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`may refer to a dictionary definition, Xilinx, Inc. v. Intellectual Ventures I LLC,
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`IPR2013–00112, Paper 51 at 9–10 (June 26, 2014), and how the claim term is used
`
`in the prior art, 3M Innovative Props. Co. v. Tredegar Corp., 725 F.3d 1315, 1326-
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`28 (Fed. Cir. 2013).
`
`Patent Owner submits that a person of ordinary skill in the art of the claimed
`
`invention at the time of the invention would have had at least a Bachelor of
`
`Science degree in computer science or a commensurate degree and a working
`
`understanding of video graphics rendering attained through either education or
`
`experience.
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`Patent Owner further submits, for only the purposes of Inter Partes Review,
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`that the claim terms are presumed to take on their broadest reasonable
`
`interpretation in light of the specification of the ‘649 Patent.
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`A.
`
`rendering/rendered
`
`
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`Each of independent claims 1, 13, and 15 recites the “second image is
`
`generated without being rendered.” At page 16 of the Petition, Petitioners assert
`
`that “rendering/rendered” means “[generating an image/generated] by using three-
`
`dimensional texturing.” Patent Owner respectfully disagrees with Petitioners’
`
`proposed construction of “rendering/rendered” because Petitioners’ proposed
`
`construction of “rendering” as being limited to “three-dimensional texturing” is
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`inconsistent with both the ordinary meaning of “rendering” as used in the ‘649
`
`patent and as would have been understood by the skilled artisan, and the ordinary
`
`meaning of “rendering” as confirmed in Petitioners’ own cited references.
`
`Rendering is not, in fact, exclusively limited to “three-dimensional texturing,” but
`
`also commonly includes numerous techniques to improve the visual impression
`
`and definition of an image. See ‘649 Patent (Ex. 1001) at 9:57-10:6-28.
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`
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`The passage in the ‘649 patent upon which the Petitioners’ rely explains that
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`texturing is merely one example of rendering to generate an image (see ‘649 patent
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`(Ex. 1001) at 9:57-62, emphasis added):
`
`The rendering is one of methods of generating an image. For
`
`example, the rendering may be used for generating an actual graphic
`image by realizing a three-dimensional texture such as the variance in
`colors and density.
`
`
`
`As discussed above, “rendering,” as used in the ‘649 patent, is not limited to
`
`texturing, but also commonly includes various other techniques that improve the
`
`visual appearance and definition of an image (see ‘649 patent (Ex. 1001) at 10:6-
`
`28, emphasis added):
`
`The substantial purpose of real-time rendering is to generate
`
`and display an image at a speed that can improve a visual appearance
`of an object as an image and make a user to sense proper interactivity.
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`In this case, various methods may be used. Particularly, the
`interactivity may be embodied by acceleration algorithms.
`
`For example, in the real-time rendering, a method of giving a
`
`definition of a material and light in order to improve the visual
`appearance and improving the definition via anti-aliasing, gamma
`correction, advanced lighting, and shading.
`
`Also, the real-time rendering may use texturing as the
`
`acceleration algorithms. The texturing is performed by a method of
`covering an image on the surface of an object. Culling and pipeline
`optimization method are used as other examples of the acceleration
`algorithms.
`
`Though the rendering is schematically described in the above,
`
`methods capable of being used in rendering are not limited as
`described above. Namely, the screen update system according to the
`present invention may render by using all methods of rendering,
`such as not only conventional methods of rendering also newly
`developed rendering methods. It is truly said that the described
`above belongs to the scope of the present invention.
`
`The meaning of “rendering” as used in the specification of the ‘649 patent is
`
`entirely consistent with the meaning of "rendering" explicitly described in both
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`Pose and Bowen, the prior art included in Petitioners’ first ground of
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`unpatentability.
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`First, Bowen discloses a system that "permits the user programmer to render
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`two- and three-dimensional objects into a frame buffer for storage as pixels, which
`
`are then transmitted by a display system … for user display.” Bowen (Ex. 1024) at
`
`4:22-26. Bowen further provides a detailed description of the rendering therein as
`
`follows:
`
`II. Rendering and Displaying Image Frames
`
`FIG. 1 illustrates a general pipeline hierarchy for the typical
`
`display system. … Host 102, running OpenGL, creates vertices
`describing the shapes of desired objects, such as points, line
`segments, and polygons. Other graphics API, languages, or systems
`can be used. OpenGL, of course, can be run without the present
`invention.
`
`Host 102 sends these vertices to a geometry system 104.
`
`Geometry system 104 will handle calculation of geometrical aspects
`of a graphical object, including lighting calculations,
`transformational calculations, rotational calculations, perspective
`calculations, and other recognized geometrical calculations. As a
`result of the geometry calculations, entities called primitives are
`formed. These primitives, sometimes referred to as “lit triangles”, are
`geometric objects with edge flags, including color and texture
`information.
`
`…
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`Geometry system 104 sends the formed primitives to
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`rasterization system 106. Rasterization system 106 rasterizes the
`primitives into two-dimensional images called fragments,
`comprising points having associated color, depth, and texture
`data. Rasterization, which is a technique recognized by those skilled
`in the art, takes the points of the lit triangles and determines the
`characteristics (colors, textures) of the intermediate points of these
`triangles. …
`
`The formed fragments are combined into pixels in frame
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`buffer environment 108. …
`
`The entire process of creating vertices at the host, using the
`
`vertices to create primitives at the geometry system, rasterizing the
`primitives to form two-dimensional fragments at the rasterization
`system, and combining the fragments into pixels for storage in the
`frame buffer, is called rendering.
`
`Bowen (Ex. 1024) at 4:46-5:44, emphasis added. See also, Bowen (Ex. 1024) at
`
`9:4-9, “Complex images place a greater burden on the processing of the
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`rasterization system 106, making for slow-downs in the rendering portion of the
`
`graphics pipeline processing,” emphasis added; compare ‘649 patent (Ex. 1001)
`
`at 10:19-20, “Culling and pipeline optimization method are used as other
`
`examples of the acceleration algorithms,” emphasis added. Bowen therefore
`
`confirms that rendering is not simply “using three-dimensional texturing,” as
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`alleged in the Petition. Rather, “[t]he entire process”—creating “vertices
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`describing the shapes of desired objects, such as points, line segments, and
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`polygons,” calculating “geometrical aspects of a graphical object, including
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`lighting calculations, transformational calculations, rotational calculations,
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`perspective calculations, and other recognized geometrical calculations” to form
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`primitives “including color and texture information,” rasterizing “the primitives
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`into two-dimensional images called fragments, comprising points having
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`associated color, depth, and texture data,” and combining image fragments “into
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`pixels in frame buffer environment”—”is called rendering.” Bowen (Ex. 1024),
`
`supra.
`
`Second, Pose relates to rendering in virtual reality systems. See e.g., Pose
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`(Ex. 1023) at 1:6-17. “As the polygon rendering rate directly effects the scene
`
`realism and scene fluidity, many researchers attempt to improve the performance
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`of their systems by {focusing} mainly upon the polygon rendering engine.” Pose
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`(Ex. 1023) at 2:51-55. “After creation of the scene the computationally expensive
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`rendering process can commence. Upon completion of the frame drawing process
`
`the image is ready to be displayed.” Pose (Ex. 1023) at 11:67-12:3.
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`When generating a scene for a virtual reality system there
`
`appears to be several processes being undertaken. For ease of
`reference, these processes have been divided roughly into two major
`categories. The first category is scene animation and encompasses
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`processes such as object movement within the virtual world, user
`translation within the virtual world and lighting or shadowing
`changes within the scene. The second process is scene maintenance
`and refers to updating the display based upon user gestures such as
`head rotations. A Static Virtual Environment SVE is defined an
`environment in which only scene maintenance is required. … The
`rendering engines may then use all of their resources for
`animations within the scene and initial scene creation.…
`
`In order to generate an entire scene independent of
`
`orientation the image can be thought of as being rendered onto an
`encapsulating surface surrounding the user’s head. A spherical
`encapsulating surface has been contemplated, in which the spherical
`surface is mapped into display memory using a spherical coordinate
`system, with uniformly spaced φ units mapping to the columns and
`uniformly spaced θ values mapped to the rows of the display memory.
`Such a mapping scheme for the sphere results in varied pixel densities
`within the display memory. As such, an ellipsoid or cube may prove
`to be a better choice of encapsulating surface when considering
`uniformity of pixel storage within display memory.
`
`All user translations, lighting and shadowing changes,
`
`stereoscopy and object animation require some form of
`redrawing. Any form of redrawing falls into the category of scene
`animation. Although the rendering engine is responsible for scene
`animation, the display controller accommodates depth buffers.
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`This allows different sections of the scene to be rendered to different
`display memories ordered by depth. …
`
`Display generation generally consists of two processes. The
`
`first process interfaces the video memory to the CPU and is referred to
`as the rendering engine. This stage may be implemented in hardware
`or software. The rendering engine, in effect, draws the image into
`the video memory. The second process sends the image drawn by the
`rendering engine to the display device and is referred to as the display
`controller. Such a system is shown in FIG. 3.
`
`Pose (Ex. 1023) at 12:41-13:65, emphasis added. Pose therefore also confirms that
`
`rendering is not simply “using three-dimensional texturing,” as alleged in the
`
`Petition. Instead, rendering includes “scene animation and encompasses processes
`
`such as object movement within the virtual world, user translation within the
`
`virtual world and lighting or shadowing changes within the scene.” Pose (Ex.
`
`1023), supra. Compare Bowen (Ex. 1024) at 4:59-67, “calculation of geometrical
`
`aspects of a graphical object, including lighting calculations, transformational
`
`calculations, rotational calculations, perspective calculations, and other recognized
`
`geometrical calculations; and compare ‘649 patent at 10:12-15, “in the real-time
`
`rendering, a method of giving a definition of a material and light in order to
`
`improve the visual appearance and improving the definition via anti-aliasing,
`
`gamma correction, advanced lighting, and shading.” “The rendering engines may
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`then use all of their resources for animations within the scene and initial scene
`
`creation.” Pose (Ex. 1023), supra. “All user translations, lighting and shadowing
`
`changes, stereoscopy and object animation require some form of redrawing. Any
`
`form of redrawing falls into the category of scene animation … the rendering
`
`engine is responsible for scene animation.” Pose (Ex. 1023), supra.
`
`Accordingly, in addition to the ‘649 patent, each of Pose and Bowen
`
`confirms that “rendering” is directed to various image processing calculations
`
`performed on image data prior to storing the processed data (i.e., pixel data) in a
`
`frame buffer, including rasterization, color control, lighting control, and polygon
`
`calculation. Therefore, contrary to Petitioners’ allegation, a broadest reasonable
`
`interpretation of “rendering,” as would have been understood by the artisan of
`
`ordinary skill, is not limited solely to texturing.
`
`In view of the above, the artisan of ordinary skill would have understood a
`
`broadest reasonable interpretation of “rendered/rendering” to be image processing
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`of image data for improving the visual appearance of an object in an image.
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`B. “second image data not being loaded on a buffer”
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`Each of claims 13 and 15 recites the “second image data not being loaded on
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`a buffer.” Consistent with the disclosure in the ‘649 patent and the language of
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`other features in these claims, the broadest reasonable interpretation of this feature
`
`is that the second image is not loaded on any buffer.
`
`Portions of claim 13 that precede “second image data not being loaded on a
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`buffer” recite “…sequentially load the identified image resource data for each
`
`buffer by frame in a buffer space including a plurality of the buffers” and
`
`“…sequentially determine the image resource data loaded on the buffer.” Claim 15
`
`includes similar preceding recitations “…sequentially loading the identified image
`
`resource data for each buffer by frame in a buffer space including a plurality of the
`
`buffers” and “…sequentially determining the image resource data loaded on the
`
`buffer.”
`
`Accordingly, the limitation “a buffer” within the later recitation does not
`
`have antecedent basis in the earlier recited “each buffer by frame in a buffer space
`
`including a plurality of the buffers.” Instead, consistent with the specification of
`
`the ‘649 patent, “a buffer” as used in “second image data not being loaded on a
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`buffer” means that the second image is not loaded on any buffer, not just the
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`previously recited buffer among the plurality of buffers. See CAE Screenplates
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`Inc. v. Heinrich Fiedler GmbH & Co. KG, 224 F.3d 1308, 1317 (Fed. Cir. 2000)
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`(holding there is a presumption that when different words are used to describe
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`different elements they have different meanings).
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`15
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`Case IPR2016-01880
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`Regarding this lack of buffering, the ‘649 patent discloses that, when a
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`mouse is the second image, the second image is “directly” generated without the
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`image resource data being loaded in the buffer space (see ‘649 patent (Ex. 1001) at
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`6:63-67):
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`… The screen update system 100 moves the mouse for selecting an
`item and directly generates the second image to reflect on the game
`screen, instead of loading the image resource data associated with
`displaying the selected item on the buffer space.
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`The ‘649 patent also discloses that, “[s]ince the second image is generated
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`without being loaded onto the buffer means and there is a small amount of
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`computation required to generate the second image, the second image may be
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`generated at a higher speed than the first image.” See ‘649 patent (Ex. 1001) at 7:4-
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`7.
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`As a result, in view of the specification of ‘649 patent and the internal claim
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`language, the broadest reasonable interpretation of the “second image data not
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`being loaded on a buffer,” recited in claims 13 and 15 means that the second image
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`is not loaded on any buffer.
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`C. “in a buffer space including a plurality of buffers, in which the image
`resource data are loaded in rotation on the buffer by frame, respectively”
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`
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`Claim 1 of the ‘649 patent requires that identified image resource data
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`associated with an update event for a first image is loaded “in a buffer space
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`PATENT OWNER PRELIMINARY RESPONSE TO IPR PETITION
`Case IPR2016-01880
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`including a plurality of buffers, in which the image resource data are loaded in
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`rotation on the buffer by frame, respectively.” This feature means that each frame
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`of the image resource data for the first image is alternatingly loaded between
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`respective buffers of a plurality of buffers within a buffer space. For example, the
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`‘649 patent describes alternating between respective buffers as what is meant by
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`“loaded in rotation” (see ‘649 patent (Ex. 1001) at 3:34-41):
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`4) Loaded on Rotation in a Buffer
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`A processor means loads image resource data in rotation on a
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`plurality of buffers from a basic recording space. For example, in a
`case where two buffers such as a first buffer and a second buffer are
`used, the image resource data is sequentially loaded on each of the
`buffers, such as the first buffer  the second buffer  the first buffer
`, which is indicated as a term of “loaded in rotation”.
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`Moreover, the ‘649 patent provides a probative example of how the
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`image data is “loaded in rotation” (see ‘649 patent (Ex. 1001) at 5: 37-67):
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`Next, in Step 203, the identified image resource data is loaded
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`on a buffer space including a plurality of buffers. The image resource
`data are loaded in rotation on the buffers by a frame, respectively.
`The first image of a frame is used for generating a full image as
`following.
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`In the present embodiment, it is described as an example that
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`the buffer space for loading the image resource data includes two
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`PATENT OWNER PRELIMINARY RESPONSE TO IPR PETITION
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`buffers such as a first buffer and a second buffer. On the other hand, a
`buffer space including not less than three buffers according to
`embodiments. Also, the basic recording space and the buffer space
`may be embodied in a recording device that is physically or logically
`distinguished.
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`The screen update system 100 sequentially loads the identified
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`image resource data on the first buffer and the second buffer by a
`frame. For example, in case that the first image of thirty frames are
`sequentially generated from a first frame to a thirtieth frame,
`respectively, if the image resource data corresponding to the first
`frame is loaded on the first buffer, the image resource data
`corresponding to the second frame may be loaded on the second
`buffer. As following, after the first image is generated by using the
`image resource data loaded on the first buffer, the image resource data
`corresponding to a third frame is loaded on the first buffer. As
`described above, the image resource data corresponding to each frame
`is sequentially loaded, repeatedly on the first buffer and the second
`buffer.
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`Namely, the image resource data from the first frame to the
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`thirtieth frame are loaded in order on the first buffer and second buffer
`in turn and are rendered in order to guarantee to sequentially update
`the first image, thereby providing a natural game screen to the gamer.
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`Accordingly, the broadest reasonable interpretation of the limitation
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`that the image resource data associated with an update event for a first image
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`PATENT OWNER PRELIMINARY RESPONSE TO IPR PETITION
`Case IPR2016-01880
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`is loaded “in a buffer space including a plurality of buffers, in which the
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`
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`image resource data are loaded in rotation on the buffer by frame,
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`respectively” is that each frame of the image resource data for the first image
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`is alternatingly loaded between respective buffers of a plurality of buffers
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`within a buffer space.
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`D. “generating the first image at a first frame rate” and “generating a second
`image … at a second frame rate”
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`Each of independent claims 1, 13, and 15 recites “generating the first image
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`at a first frame rate” and “generating a second image … at a second frame rate.”
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`First, consistent with the plain language of the claims and the disclosure in
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`the ‘649 patent, the broadest reasonable interpretation of this feat