UNITED STATES PATENT AND TRADEMARK OFFICE
`——————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`——————————
`
`Axis Communications AB, Canon Inc., and Canon U.S.A., Inc.,
`
`Petitioner
`
`v.
`
`Avigilon Fortress Corporation,
`
`Patent Owner
`——————————
`Case: IPR2019-00236
`
`U.S. Patent No. 7,868,912
`Issue Date: January 11, 2011
`
`Title: Video Surveillance System Employing Video Primitives
`——————————
`DECLARATION OF JOHN R. GRINDON, D.Sc.
`
`

`

`TABLE OF CONTENTS
`BACKGROUND AND QUALIFICATIONS ................................................. 2
`I.
`II. MATERIALS CONSIDERED ........................................................................ 7
`III. LEGAL STANDARDS FOR PATENTABILITY ........................................10
`A. Anticipation Analysis: 35 U.S.C. § 102 ..............................................11
`B.
`Obviousness Analysis: 35 U.S.C. § 103 .............................................12
`IV. THE ’912 PATENT .......................................................................................17
`A. Overview .............................................................................................17
`B.
`Prosecution History .............................................................................21
`1.
`Original Examination ................................................................21
`2.
`Inter partes and ex partes reexamination .................................22
`3.
`Prior Proceedings Involving Related Patents............................23
`Level of Ordinary Skill in the Art .......................................................25
`C.
`CLAIM CONSTRUCTION ..........................................................................26
`A.
`Single Processor or Multiple Processors (claims 6-22) ......................27
`B.
`“filtering” .............................................................................................28
`C.
`Independence-based limitations ..........................................................31
`1.
`Independence Argument (1): requires identifying an event that
`refers to one or more objects engaged in an activity by
`analyzing the detected attributes ...............................................34
`Independence Argument (3): the identified event is not one of
`the detected attributes................................................................35
`Independence Argument (2): the detected attributes are
`“independent” of the event identified or detected ....................40
`
`V.
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`2.
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`3.
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`C.
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`D.
`analyzing “only” certain attributes ......................................................49
`VI. PRIORITY DATE .........................................................................................51
`VII. OVERVIEW OF PRIOR ART ......................................................................57
`A.
`State of the Prior Art and Applicant Admitted Prior Art ....................57
`Talmon .................................................................................................59
`B.
`Aspectus ...............................................................................................62
`Brill ......................................................................................................63
`D.
`E. Motivation to Combine Talmon with Aspectus or Brill ......................67
`1.
`Talmon and Aspectus ................................................................67
`2.
`Talmon and Brill .......................................................................68
`VIII. NEW ISSUES OF PATENTABILITY .........................................................70
`A. Dispute Regarding the Independence-Based Claim Elements in the
`Prior Proceedings ................................................................................70
`Dispute Regarding Priority Date .........................................................73
`B.
`IX. CLAIMS 1-4 and 6-36 OF THE ’912 PATENT ARE UNPATENTABLE
`OVER THE PRIOR ART ..............................................................................74
`A. Ground 1: Talmon anticipates claims 1-4 and 6-36 ............................74
`1.
`Independent Claim 1 .................................................................74
`2.
`Claims 2, 7, 10, 14, and 21 .......................................................86
`3.
`Claims 3, 8, 11 ..........................................................................87
`4.
`Claim 4 ......................................................................................89
`5.
`Independent Claim 6 .................................................................90
`6.
`Independent Claim 9 .................................................................93
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`7.
`Independent Claim 12 ...............................................................95
`Claim 13 ....................................................................................97
`8.
`Claim 15 ....................................................................................98
`9.
`10. Claim 16 ....................................................................................98
`11. Claim 17 ....................................................................................99
`12.
`Independent Claim 18 ...............................................................99
`13. Claims 19, 22 ..........................................................................104
`14. Claim 20 ..................................................................................104
`15. Claims 23-25 ...........................................................................105
`16. Claims 26-29 ...........................................................................109
`17. Claims 30-33 ...........................................................................113
`18. Claims 34-36 ...........................................................................118
`Grounds 2-3: Obviousness of Claims 1-4, 6-36 ................................119
`1.
`“event that is not one of the [determined/detected] attributes”
`and “combination of the [received] [determined] attributes” [All
`Claims] ....................................................................................119
`Claims 3, 8, 11 ........................................................................121
`2.
`Claim 18 – Talmon in view of Aspectus or Brill ....................124
`3.
`Claims 26-33 – Talmon in view of Aspectus or Brill .............124
`4.
`CONCLUSION ............................................................................................125
`
`B.
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`X.
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`I, Dr. John R. Grindon, declare as follows:
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`1.
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`I make this Declaration based upon my own personal knowledge and,
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`if called upon to testify, would testify competently to the matters stated herein.
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`2.
`
`I have been asked by Axis Communications AB, Canon Inc., and
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`Canon U.S.A., Inc. (collectively “Petitioner”) to provide technical assistance in
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`connection with the Petition for inter partes review of U.S. Patent No. 7,868,912
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`(“the ’912 patent”). This Declaration, which I understand will be filed with the
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`Petition, is a statement of certain opinions I have formed on issues related to the
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`patentability of claims 1-4 and 6-36 of the ’912 patent.
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`3.
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`It is my opinion that each of claims 1-4 and 6-36 of the ’912 Patent is
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`unpatentable in view of the identified prior art. My opinions are stated in detail in
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`this Declaration, with reference to the exhibits attached to the Petition and any
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`additional exhibits attached to my Declaration.
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`4.
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`I am being paid at my customary rate of $500 per hour for my time
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`spent in study, preparation, and testifying in this matter. I am also being
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`reimbursed for reasonable and customary expenses associated with my work. No
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`portion of my compensation is dependent or otherwise contingent upon the
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`specifics of my testimony or the results of this matter. My compensation is not
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`contingent upon the outcome of this inter partes review.
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`I.
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`BACKGROUND AND QUALIFICATIONS
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`5. My name is John R. Grindon. I reside in Hazelwood, Missouri. I have
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`been retained by Petitioner as an expert witness for this matter. I am competent to
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`testify regarding the opinions set forth in this expert Declaration. I reserve the right
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`to provide further opinions if requested at a later time.
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`6. My qualifications are summarized here and are presented further in
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`my curriculum vitae, which is attached as Exhibit 1036 to the Petition. I received a
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`Bachelor of Science (B.S.) degree in Electrical Engineering, with First Honors,
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`from the University of Missouri at Rolla, now the Missouri University of Science
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`and Technology. I received a Master of Science (S.M.) degree in Electrical
`
`Engineering from the Massachusetts Institute of Technology, and a Doctor of
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`Science (D.Sc.) degree in Electrical Engineering from Washington University in
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`St. Louis.
`
`7.
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`During my university studies, I was awarded the Westinghouse
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`Achievement Scholarship. I was a Hughes Masters Fellow at M.I.T. My doctoral
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`research at Washington University was in the field of signal processing.
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`8.
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`I have more than 40 years of experience including research, analysis,
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`design and development of electronic systems and software for acquiring,
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`processing, analyzing, extracting information from, and communicating signals
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`and images. This work includes technology related to that disclosed in the ’912
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`patent. I have experience in both hardware and software for this technology.
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`9.
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`For more than 20 years, I have provided independent consulting,
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`including in the areas of technology related to the ’912 patent. From 1987 until
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`1990, I served as Executive Vice President and Director of Research at the former
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`Cencit, Inc. Cencit was an engineering research and development company that
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`created systems for sensing and digitizing the shape of three-dimensional (“3D”)
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`objects through processing of images. The systems generated 3D data about an
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`object based on data gathered from video image sequences that included the object.
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`The 3D data was extracted from the sequences of video images acquired by video
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`cameras viewing the objects. These systems employed processors, communications
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`and control circuits, memory storage and retrieval capabilities, and software
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`algorithms for identifying image primitives, object extraction, location, and 3D
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`surface mapping. Several U.S. and foreign patents were awarded. For more
`
`information about the technology developed at Cencit, see for example U.S. Patent
`
`No. 4,846,577, filed in April 1987, issued in July 1989.
`
`10. The systems developed by Cencit were implemented for a variety of
`
`uses. For example, one system was used for craniofacial trauma research by the
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`Washington University School of Medicine. Another system was used by the
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`United States Army for research into leak proof fitting of gas masks for biological
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`warfare. Other applications included the 3D modeling of Space Shuttle astronaut’s
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`hands for custom fitting of gloves for use with spacesuits and scanning of the
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`heads of brain tumor patients for precisely positioning implanted radioactive seeds.
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`11. Later, I also helped to develop a 3D shape digitization system for the
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`Textile/Clothing Technology Corporation (“TC-Squared”) of Cary, North
`
`Carolina. This system extracted 3D data of a human body from sequences of
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`images, for the original purpose of fabricating custom-fit clothing. Using a
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`different technology than the Cencit system, but also based upon multiple video
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`cameras, the TC-Squared system employed sinusoidal patterns of light projected
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`onto the subject. A first sequence of coarse sinusoidal patterns was used to
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`generate a sparse set of 3D contours. These 3D contours were unambiguously
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`identified. A second sequence, of fine sinusoidal patterns, was then projected
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`which produces high-resolution 3D contours, but with ambiguities for phase angle
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`multiples of 360°. The 3D contour identifications from the coarse patterns were
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`then used to unambiguously identify, or map, the high-resolution 3D contours that
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`were generated from the fine grating projections. Multiple 3D contours were
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`created using the multiple cameras, each covering a portion of the subject, and
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`these contours were then combined into a uniform composite 3D map of the shape
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`of the object. This system is described in further detail for example in a patent by
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`4
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`me and several co-inventors, U.S. Patent No. 6,373,963, filed in February 1999,
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`issued in April 2002.
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`12. My role in the development of the TC-Squared system included
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`among other things development of a design concept, providing technical guidance
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`to the engineering team, analyzing and predicting performance parametrically
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`during the design process, defining system parameters and specifications,
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`development of processing algorithms, and development of camera and system
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`calibration methods and software.
`
`13. During my 25 years at McDonnell Douglas Corporation, now Boeing,
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`from 1962-1987, I started with the title of Engineer and progressed through various
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`positions of increasing responsibility to the position of Branch Chief, Electronics.
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`Among other things, my work there included digital image processing research and
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`development for autonomous cruise missile guidance. This work was based on
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`employing on-board digital video cameras and radar to sense terrain and targets,
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`and processing of the imagery and radar data to derive information, such as shape
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`of the terrain surface and identification of targets from the video images. This work
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`also employed correlating images acquired by an on-board video camera with
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`stored reference images. I also developed algorithms for missile-borne laser radar
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`systems (LIDAR) for processing sequences of depth images to detect objects for
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`the purpose of enabling low-flying cruise missiles to avoid collisions, for example
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`with power wires in their path.
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`14. Among other work in image processing at McDonnell Douglas, I led
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`an image processing research and development team, where we developed
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`algorithms for target recognition and classification. This work included extracting
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`primitive features from images and development of classifier algorithms to use the
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`extracted features for identifying and locating objects in the images. I also
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`managed a team to develop algorithms for an automatic target classification and
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`recognition system using on-board infrared (“IR”) cameras. I also developed a new
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`class of image processing algorithms for autonomous cruise missile location and
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`guidance using IR cameras to acquire video image sequences of the scenes ahead
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`of the missile, correlating the scene images with stored reference data for vehicle
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`position tracking.
`
`15.
`
`I have been qualified as a technical expert for several litigation and
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`patent review matters involving video image acquisition, image processing, image
`
`analysis, video surveillance, and information extraction. My expert analysis and
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`testimony has involved patents related to digital video imaging and image
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`processing systems, including those for sensing and measuring the shape and
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`location of objects. My curriculum vitae, attached as Exhibit 1036 to the Petition,
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`includes a listing of matters of public record for which I have served as an expert
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`and offered testimony at deposition or trial in at least the last five years.
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`II. MATERIALS CONSIDERED
`
`16.
`
`I understand that the Petition and this inter partes review proceeding
`
`involves the ’912 patent, which is owned by Avigilon.
`
`17.
`
`I further understand that the ’912 patent issued from U.S. Application
`
`No. 11/098,385 (the “’385 application”). This is reflected on the face of the
`
`’912 patent (Ex. 1001).
`
`18. The face of the ’912 patent also indicates that the earliest priority date
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`it may claim is October 24, 2000, based on the filing date of U.S. Patent No.
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`6,954,498. In Section VI below, I explain my opinion regarding the earliest priority
`
`date to which the claims of the ’912 patent are entitled.
`
`19.
`
`I understand that prior art to the ’912 patent includes all inventions
`
`known (e.g., published) or used in the U.S., patent applications filed before the
`
`earliest possible priority date, or publications published more than one year before
`
`the priority date claimed by the ’912 patent, which, as explained in Section VI
`
`below, is April 5, 2005.
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`20.
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`I have been asked to consider whether certain prior art references
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`(namely, Talmon, Aspectus, and Brill) disclose or suggest the features recited in the
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`claims of the ’912 patent. I have also been asked to consider the state of the art in
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`the 2005 timeframe (i.e., before the priority date of April 5, 2005 (see Section VI)),
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`and to compare the claims of the ’912 patent to the prior art available at that time.
`
`21.
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`I have reviewed and considered the following documents, among
`
`others identified herein, in connection with my analysis of the ’912 patent and this
`
`Declaration:
`
`• U.S. Patent No. 7,868,912 B2 to Venetianer et al. and Reexamination
`
`Certificate 7,868,912 C1 (“the ’912 patent,” Ex. 1001);
`
`• Prosecution history of U.S. Application No. 11/098,385, filed April 5, 2005,
`
`which led to the issuance of the ’912 patent (Ex. 1002);
`
`• The Applications to which the ’912 patent claims priority: U.S. Application
`
`No. 09/694,712, filed October 24, 2000 (“the ’712 application,” Ex. 1037);
`
`U.S. Application No. 09/987,707, filed November 15, 2001 (“the ’707
`
`application,” Ex. 1038); and U.S. Application No. 11/057,154, filed
`
`February 15, 2005 (“the ’154 application,” Ex. 1039)
`
`• Ex Parte Reexamination Control No. 90/012,878, the ex parte reexamination
`
`of the ’912 patent (see, e.g., Exs. 1013-1019);
`
`• Inter Partes Reexamination Control No. 95/001,912, the inter partes
`
`reexamination of the ’912 patent (see, e.g., Exs. 1008-1012);
`
`• U.S. Patent No. 7,932,923 B2 and Reexamination Certificate 7,932,923 C1
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`(“the ’923 patent,” Ex. 1034), which is related to the ’912 patent;
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`• Ex Parte Reexamination Control No. 90/012,876, the ex parte reexamination
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`of the ’923 patent (see, e.g., Exs. 1026-1033);
`
`• Inter Partes Reexamination Control No. 95/001,914, the inter partes
`
`reexamination of the ’923 patent (see, e.g., Exs. 1024-1025);
`
`• U.S. Patent No. 8,564,661 B2 (“the ’661 patent,” Ex. 1035), which is related
`
`to the ’912 patent;
`
`• Inter Partes Review Control No. IPR2018-00138, an inter partes review of
`
`the ’661 patent;
`
`• Inter Partes Review Control No. IPR2018-00140, an inter partes review of
`
`the ’661 patent;
`
`• U.S. Patent No. 8,004,563 to Gad Talmon et al. (“Talmon,” Ex. 1003); and
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`• “Event Recognition and Reliability Improvements for the Autonomous
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`Video Surveillance System” by Frank Brill et al. (“Brill,” Ex. 1004)
`
`• “Aspectus Video Intelligence VI-SystemTM” Brochure (“Aspectus,” Ex.
`
`1005)
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`• Declaration of Gad Talmon (Ex. 1023)
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`22. My opinions are also based on my experience in video image
`
`acquisition, image processing, image analysis, video surveillance, and information
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`extraction.
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`III. LEGAL STANDARDS FOR PATENTABILITY
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`23.
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`I have been asked to provide my opinions as to whether the identified
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`prior art (namely, Talmon, Aspectus, and Brill) teach or render obvious claims 1-4
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`and 6-36 of the ’912 patent from the perspective of a person of ordinary skill in the
`
`art (“POSITA”) in the 2005 timeframe.
`
`24.
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`I am an electrical engineer and innovator by training and profession.
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`The opinions I express in this Declaration involve the application of my technical
`
`knowledge and experience to the evaluation of certain prior art with respect to the
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`’912 patent.
`
`25. My opinions are also formed by my understanding of the relevant law.
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`I am not an attorney. Therefore, for purposes of this Declaration, I have been
`
`informed about certain aspects of the law as it relates to my opinions.
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`26.
`
`I understand that for an invention claimed in a patent to be found
`
`patentable, it must be (among other things) new and not obvious based on what
`
`was known before the invention was made.
`
`27.
`
`I understand that the information that is used to evaluate whether an
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`invention was new and not obvious when made is generally referred to as “prior
`
`art.” I understand that the prior art includes patents and printed publications that
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`existed before the earliest filing date of the patent (which I have been informed is
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`called the “effective filing date”). I also understand that a patent or published
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`patent application is prior art if it was filed before the effective filing date of the
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`claimed invention and that a printed publication is prior art if it was publicly
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`available before the effective filing date. As noted above, I understand that prior art
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`relative to the ’912 patent includes all patents or printed publications that were
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`published in the U.S. or filed before April 5, 2005.
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`28.
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`I understand that in this inter partes review proceeding, the claims
`
`must be given their broadest reasonable interpretation consistent with the patent
`
`specification, as understood by a person of ordinary skill in the art. After the
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`claims are construed in this manner, they are then compared to the prior art.
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`29.
`
`I understand that a dependent claim is a patent claim that refers back
`
`to another patent claim. A dependent claim, as I understand it, includes all of the
`
`limitations of the claim to which it refers.
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`30.
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`I understand that in this inter partes review proceeding, the
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`information that may be evaluated is limited to patents and printed publications.
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`My analysis, which is set out in detail below, compares the claims to printed
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`publications that I understand are prior art to the claims.
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`A. Anticipation Analysis: 35 U.S.C. § 102
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`31.
`
`I understand that a person cannot obtain a patent on an invention if the
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`prior art included that invention.
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`If an invention is not new, then the invention has been “anticipated”
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`32.
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`by the prior art.
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`33. A claim is “anticipated” by the prior art if each and every limitation of
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`the claim is disclosed, expressly or inherently, in a single item of prior art, from
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`which a person of ordinary skill in the art could practice the invention.
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`B. Obviousness Analysis: 35 U.S.C. § 103
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`34.
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`It is my understanding that a claim is unpatentable if the claimed
`
`subject matter as a whole would have been obvious to a person of ordinary skill in
`
`the art at the time of the alleged invention. I also understand that an obviousness
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`analysis takes into account the scope and content of the prior art, the differences
`
`between the claimed subject matter and the prior art, and the level of ordinary skill
`
`in the art at the time of the invention.
`
`35.
`
`I understand that a claimed invention is not patentable if it would have
`
`been “obvious” to a person of ordinary skill in the field of the invention at the time
`
`the invention was made. This means that even if all the requirements of a claim are
`
`not found in a single prior art reference, the claim is not patentable if the
`
`differences between the subject matter in the prior art and the subject matter in the
`
`claim would have been obvious to a person of ordinary skill in the art at the time
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`the application was filed.
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`In determining the scope and content of the prior art, it is my
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`36.
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`understanding that a reference is considered relevant prior art to the ’912 patent if
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`it falls within the field of the inventor’s endeavor. In addition, a reference is prior
`
`art if it is reasonably pertinent to the particular problem with which the inventor
`
`was involved. A reference is reasonably pertinent if it logically would have
`
`commended itself to an inventor’s attention in considering his problem. Thus, if a
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`reference relates to the same problem as the claimed invention, that supports use of
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`the reference as prior art in an obviousness analysis.
`
`37.
`
`In my opinion, the prior art references identified in the Petition and
`
`addressed in this Declaration (including, Talmon, Aspectus, and Brill) seek to solve
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`the same types of problems as the ’912 patent and logically would have
`
`commended themselves to an inventor’s attention considering the problems of the
`
`’912 patent. In particular, the ’912 patent and the identified prior art concern
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`techniques and systems for detecting objects in a video, determining attributes of
`
`the objects, and determining occurrences of events based on the attributes.
`
`38.
`
`I understand that a determination as to whether a claim would have
`
`been obvious should be based on four factors (though not necessarily in the
`
`following order): (i) the level of ordinary skill in the art at the time the application
`
`was filed; (ii) the scope and content of the prior art; (iii) the differences between
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`the claimed invention and the prior art; and (iv) any objective factors indicating
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`obviousness or non-obviousness that may exist in a particular case.
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`39.
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`It is my understanding that an obviousness analysis cannot be based
`
`on hindsight, but must be done using the perspective of a person of ordinary skill
`
`in the relevant art as of the effective filing date of the patent claim.
`
`40.
`
`I understand the objective factors indicating obviousness or non-
`
`obviousness may include: commercial success of products covered by the patent
`
`claims; a long-felt but unaddressed need for the invention; failed attempts by
`
`others to make the invention; copying of the invention by others in the field;
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`expressions of surprise by experts and those skilled in the art at the making of the
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`invention; and the patentee having proceeded contrary to the accepted wisdom of
`
`the prior art. I also understand that any of this evidence must be specifically
`
`connected to the invention rather than associated with the prior art or with
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`marketing or other efforts to promote an invention.
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`41.
`
`I understand that the teachings of two or more prior art references may
`
`be combined in the manner disclosed in the claim if such a combination would
`
`have been obvious to one having ordinary skill in the art at the effective filing date.
`
`In determining whether a combination would have been obvious, I understand that
`
`the following exemplary rationales may support a conclusion of obviousness:
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`• Combining prior art elements according to known methods to yield
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`predictable results;
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`• Simple substitution of one known element for another to obtain predictable
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`results;
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`• Use of a known technique to improve similar devices (methods, or products)
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`in the same way;
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`• Applying a known technique to a known device (method, or product) ready
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`for improvement to yield predictable results;
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`• “Obvious to try”—choosing from a finite number of identified, predictable
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`solutions, with a reasonable expectation of success;
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`• Known work in one field of endeavor may prompt variations of it for use in
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`either the same field or a different one based on design incentives or other
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`market forces if the variations are predictable to a person of ordinary skill in
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`the art; and
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`• Some teaching, suggestion, or motivation in the prior art that would have led
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`a person of ordinary skill to modify the prior art reference or to combine
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`prior art reference teachings to arrive at the claimed invention.
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`42.
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`I understand that the obviousness analysis need not seek out precise
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`teachings directed to the specific subject matter of the challenged claim, but
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`instead can take account of the ordinary innovation and experimentation in the
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`relevant field that does no more than yield predictable results.
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`43.
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`I understand that, in assessing whether there was an apparent reason to
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`modify or combine known elements as claimed, it may be necessary to look to
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`interrelated teachings of multiple patents or prior art references, the effects of
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`commercial demands, and the background knowledge of a person of ordinary skill
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`in the art. I further understand that any motivation that would have applied to a
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`person of ordinary skill in the art, including motivation from common sense or
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`derived from the problem to be solved, is sufficient to explain why references
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`would have been combined.
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`44.
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`I understand that modifications and combinations suggested by
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`common sense are important and should be considered. Common sense suggests
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`that familiar items can have obvious uses beyond the particular application being
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`described in a prior art reference, that if something can be done once it would be
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`obvious to do it multiple times, and that in many cases a person of ordinary skill in
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`the art can fit the teachings of multiple patents together in an obvious manner to
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`address a particular problem. The prior art does not need to be directed to solving
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`the same problem that is addressed in the patent.
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`45.
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`I understand that a person of ordinary skill in the art is also a person
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`of ordinary creativity. In many fields, it may be that there is little discussion of
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`obvious techniques, modifications, and combinations, and it may be the case that
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`market demand, rather than scientific research or literature, will drive a new
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`design. When there is market pressure or design need to solve a particular problem
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`and there are a finite number of identified, predictable solutions, a person of
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`ordinary skill has a good reason to employ the known options. If this leads to the
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`expected success, then it is likely the product of ordinary skill and common sense
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`as opposed to patentable innovation. I understand that if a combination was
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`obvious to try, that may show that it was obvious and therefore unpatentable. That
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`a particular combination of prior art elements was obvious to try suggests that the
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`combination was obvious even if no one made the combination.
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`IV. THE ’912 PATENT
`A. Overview
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`46. As part of my analysis, I read and considered the ’912 patent and
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`related prosecution history before the Patent Office. The following overview is not
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`meant to describe my full understanding of the ’912 patent and prosecution history,
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`but rather to highlight the general aspects of the ’912 patent and prosecution
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`history.
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`47. According to the Abstract, the ’912 patent relates to a video
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`surveillance system for extracting video “primitives” (including “attributes” of a
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`detected object) and determining the occurrence of an “event” based on the
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`primitives. Ex. 1001, Abstract. The specification goes on to specify that examples
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`of video primitives include a classification, a size, a shape, a color, a texture, a
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`position, a trajectory, a speed and direction of motion, a salient motion,
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`classification, etc. Id., 13:35-43.
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`48. The ’912 patent states that its detection and storage of primitives is
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`advantageous over conventional systems that search raw video data because it will
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`result in a reduction of the amount of data to be stored or processed as compared to
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`raw video. Id., 2:29-33. Accordingly, the disclosed surveillance system extracts
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`“primitives” or “attributes” from the video. Id., Abstract. The ’912 patent defines
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`events in terms of attributes using event discriminators. Id., 5:28-39. The ’912
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`patent describes that, using these discriminators, the “video content can be
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`reanalyzed . . . in