`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`APPLE INC.,
`Petitioner
`v.
`COREPHOTONICS LTD.,
`Patent Owner
`_______________
`
`IPR2020-00906
`U.S. Patent No. 10,225,479
`
`_______________
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
`
`
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`IPR2020-00906 Petition
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`Inter Partes Review of 10,225,479
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`TABLE OF CONTENTS
`
`PETITIONER’S EXHIBIT LIST ...................................................................... III
`I.
`INTRODUCTION .................................................................................... 1
`II. MANDATORY NOTICES ........................................................................ 1
`A.
`Real Party-in-Interest ............................................................................ 1
`B.
`Related Matters ...................................................................................... 1
`C.
`Lead and Back-up Counsel and Service Information ........................... 2
`III. GROUNDS FOR STANDING .................................................................. 2
`IV. THE ’479 PATENT ................................................................................... 2
`A.
`Summary of the Patent .......................................................................... 2
`B.
`Prosecution History and Priority Date .................................................. 6
`LEVEL OF ORDINARY SKILL IN THE ART ......................................... 7
`V.
`VI. CLAIM CONSTRUCTION ...................................................................... 7
`A.
`“to find translations between matching points in the images to
`calculate depth information and to create a fused image suited for
`portrait photos” (claim 19). ................................................................... 8
`VII. REQUESTED RELIEF ........................................................................... 10
`VIII. OVERVIEW OF CHALLENGES ........................................................... 10
`A.
`Challenged Claims ..............................................................................10
`B.
`Statutory Grounds for Challenges .......................................................10
`C.
`Discretionary Denial is Not Warranted ...............................................11
`D.
`Page Citations and Emphasis ..............................................................12
`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE .. 12
`A. Ground 1: Claims 19 and 20 are obvious over the combination of
`Parulski, Ogata, Kawamura, and Soga. ...............................................12
`1.
`Summary of Parulski .................................................................12
`2.
`Summary of Kawamura ............................................................17
`3.
`Reasons to combine Parulski and Kawamura ...........................21
`4.
`Summary of Ogata ....................................................................24
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`IX.
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`B.
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`IPR2020-00906 Petition
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`Inter Partes Review of 10,225,479
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`5.
`Reasons to combine Parulski and Ogata ...................................28
`Summary of Soga ......................................................................30
`6.
`Reasons to Combine Parulski and Soga ...................................33
`7.
`Claim 19 ....................................................................................39
`8.
`Claim 20 ....................................................................................62
`9.
`Ground 2: Claims 21 and 22 obvious over the combination of
`Parulski, Ogata, Kawamura, Soga, and Morgan-Mar. ........................64
`1.
`Summary of Morgan-Mar .........................................................64
`2.
`Reasons to Combine Parulski, Soga, and Morgan-Mar ............67
`3.
`Claim 21 ....................................................................................69
`4.
`Claim 22 ....................................................................................71
`CONCLUSION ....................................................................................... 75
`X.
`XI. CERTIFICATE OF WORD COUNT ...................................................... 76
`CERTIFICATE OF SERVICE .......................................................................... 77
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`IPR2020-00906 Petition
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`Inter Partes Review of 10,225,479
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`PETITIONER’S EXHIBIT LIST
`May 6, 2020
`
`APPL-1001 U.S. Patent No. 10,225,479 to Shabtay et al. (the “’479 Patent”)
`
`APPL-1002 Prosecution history of the ’479 Patent (the “’242 App”)
`
`APPL-1003 Declaration of Dr. Fredo Durand Ph.D.
`
`APPL-1004 CV of Dr. Fredo Durand
`
`APPL-1005 U.S. Patent No. 7,859,588 to Parulski et al. (“Parulski”)
`
`APPL-1006
`
`JP Patent Application Publication No. 2007-259108 to Soga
`(“Soga”), English Translation, Declaration, and Original
`
`APPL-1007
`
`Jacobs et al., “Focal Stack Compositing for Depth of Field
`Control,” Stanford Computer Graphics Laboratory Technical
`Report 2012-1
`
`APPL-1008 Prosecution history Morgan-Mar
`
`APPL-1009 U.S. Patent No. 8,989,517 to Morgan-Mar et al. (“Morgan-Mar”)
`
`APPL-1010 PCT Publication No. WO2013140359 to Shalon et al. (“Shalon”)
`APPL-1011 U.S. Patent Application Publication No. 2008/0030592 to Border
`et al. (“Border”)
`
`APPL-1012
`
`JPS5862609A to Kawamura (“Kawamura”)
`
`APPL-1013 Used in co-filed Petition
`
`APPL-1014 U.S. Patent No. 6,259,863 to Maruyama (“Maruyama”)
`
`APPL-1015 Used in co-filed Petition
`APPL-1016 Ralph E. Jacobson et al., The Manual of Photography:
`photographic and digital imaging, 9th Edition, 2000 (“Jacobson”)
`APPL-1017 U.S. Patent App. Pub. No. 2010/0321511 to Koskinen et al.
`(“Koskinen”)
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`APPL-1018 U.S. Patent No. 7,206,136 to Labaziewicz et al. (“Labaziewicz”)
`APPL-1019 Milton Katz, INTRODUCTION TO GEOMETRICAL OPTICS
`(2002) (“Katz”)
`
`APPL-1020 Warren J. Smith, MODERN LENS DESIGN (1992) (“Smith”)
`
`APPL-1021 Declaration of Dr. Jose Sasián, Ph.D.
`
`APPL-1022
`
`ZEMAX Development Corporation, ZEMAX Optical Design
`Program User’s Manual, February 14, 2011 (“ZEMAX User’s
`Manual”)
`
`APPL-1023 Used in co-filed Petition
`
`APPL-1024 Used in co-filed Petition
`
`APPL-1025 Used in co-filed Petition
`
`APPL-1026 U.S. Patent No. 5,546,236 to Ogata et al. (“Ogata”)
`
`APPL-1027 Used in co-filed Petition
`APPL-1028 Bae et al., “Defocus Magnification,” EUROGRAPHICS 2007,
`(“Bae”)
`
`APPL-1029 Specification sheet for Sony ICX629 image sensor (“ICX629”)
`
`APPL-1030 Specification sheet for Sony ICX624 image sensor (“ICX624”)
`
`APPL-1031 Used in co-filed Petition
`
`APPL-1032 Used in co-filed Petition
`
`APPL-1033 Product manual for Kodak Easyshare V610
`
`APPL-1034 Used in co-filed Petition
`
`APPL-1035 Robert E. Fischer et al., OPTICAL SYSTEM DESIGN (2008)
`
`APPL-1036 Email from Patent Owner’s counsel authorizing electronic service
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`I.
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`IPR2020-00906 Petition
`Inter Partes Review of 10,225,479
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`INTRODUCTION
`U.S. Patent No. 10,225,479 (the “’479 Patent,” APPL-1001) is generally
`
`directed to a “dual aperture” digital camera. APPL-1001, Title. The claims
`
`challenged in this Petition recite two sets of limitations— (1) wide and tele
`
`cameras with overlapping fields of view (FOVs) and (2) a camera controller that
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`provides two functions: (1) “to find translations between matching points in the
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`images to calculate depth information” and (2) “to create a fused image suited for
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`portrait photos.” Id., 15:28-31. As shown in this Petition, these concepts were
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`known in the art prior to the ’479 Patent.
`
`This Petition, along with the cited evidence, demonstrates that claims 19-22
`
`of the ’479 Patent (“the challenged claims”) are obvious under 35 U.S.C. § 103.
`
`Petitioner Apple Inc. requests that these claims be held unpatentable and cancelled.
`
`II. MANDATORY NOTICES
`A. Real Party-in-Interest
`The real party-in-interest is Apple Inc.
`
`B. Related Matters
`As of the filing date of this Petition and to the best knowledge of Petitioner,
`
`the ’479 Patent has been asserted in the following matters:
`
`• Corephotonics Ltd. v. Apple Inc., Case No. 5-19-cv-04809 (N.D. Cal.
`filed August 14, 2019).
`
`• Petitioner is concurrently filing IPR2020-00905 directed to claims 1-
`16, 18, 23-38, and 40.
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`IPR2020-00906 Petition
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`Inter Partes Review of 10,225,479
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`C. Lead and Back-up Counsel and Service Information
`Lead Counsel
`
`Michael S. Parsons
`972-739-8611
`Phone:
`214-200-0853
`HAYNES AND BOONE, LLP
`Fax:
`2323 Victory Ave. Suite 700
`michael.parsons.ipr@haynesboone.com
`Dallas, TX 75219
`USPTO Reg. No. 58,767
`
`
`Back-up Counsel
`
`Andrew S. Ehmke
`214-651-5116
`Phone:
`214-200-0853
`HAYNES AND BOONE, LLP
`Fax:
`2323 Victory Ave. Suite 700
`andy.ehmke.ipr@haynesboone.com
`Dallas, TX 75219
`USPTO Reg. No. 50,271
`Jordan Maucotel
`Phone:
`(972) 739-8621
`HAYNES AND BOONE, LLP
`Fax:
`(214) 200-0853
`2323 Victory Ave. Suite 700
`jordan.maucotel.ipr@haynesboone.com
`Dallas, TX 75219
`USPTO Reg. No. 69,438
`
`Please address all correspondence to lead and back-up counsel. Petitioner
`
`consents to electronic service.
`
`III. GROUNDS FOR STANDING
`Pursuant to 37 C.F.R. §42.104(a), Petitioner certifies that the ’479 Patent is
`
`available for inter partes review and that Petitioner is not barred or estopped from
`
`requesting an inter partes review challenging the claims on the grounds identified
`
`in this Petition.
`
`IV. THE ’479 PATENT
`Summary of the Patent
`A.
`The ’479 Patent describes a “dual-aperture zoom digital camera operable in
`
`both still and video modes.” APPL-1001, Abstract. Figure 1A diagrams the
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`patent’s camera as a dual-aperture Zoom imaging system 100 including a first
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`Wide imaging section and a second Tele imaging section, with each section having
`
`respective lenses and image sensors:
`
`Wide
`Camera
`
`Camera
`Controller
`
`Telephoto
`Camera
`
`APPL-1001, Fig. 1A (annotated).
`
`Figure 2 of the ’479 Patent illustrates the respective fields of view (FOVs) of
`
`
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`
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`the Wide and Tele image sensors:
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`Wide FOV
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`Narrow FOV
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`
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`APPL-1001, Fig. 2 (annotated). The larger FOV for the Wide image is provided by
`
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`Wide sensor 202 and the corresponding smaller FOV for the Tele image is
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`provided by Tele sensor 204. See id., 6:1-2.
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`With Wide and Tele images captured from the respective cameras, the ‘479
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`Patent describes performing several image processing methods. In the method that
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`forms the subject of the challenged claims, the image processing performs two
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`separate functions— “find[ing] translations between matching points in the images
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`to calculate depth information” and “creat[ing] a fused image suited for portrait
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`photos” with a depth of field shallower than the depth of field of the Tele image.
`
`Id., 15:25-32.
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`Regarding the process for calculating depth information, the ’479 Patent
`
`only describes this for the purposes of fast focusing of an autofocus mechanism.
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`Id., 12:12-15 (“The result is fast focusing.”). This process first performs
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`registration “between the Wide and Tele images to output a transformation
`
`coefficient…. The transformation coefficient includes the translation between
`
`matching points in the two images” that is “measured in a number of pixels. Id.,
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`12:7-11. The different translations between the images “result in a different
`
`number of pixel movements between matching points in the images.” Id., 12:11-
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`12. The pixel movements are “translated into depth” and then “translated into an
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`AF position.” Id., 12:12-15.
`
`Regarding the process for creating a fused image with a shallower depth of
`
`field, the ’479 Patent describes that:
`
`In some embodiments, a dual-aperture zoom system
`disclosed herein can be used to capture a shallow DOF
`photo (shallow compared with a DOF of a Wide camera
`alone), by taking advantage of the longer focal length of
`the Tele lens. The reduced DOF effect provided by the
`longer Tele focal length can be further enhanced in the
`final image by fusing data from an image captured
`simultaneously with the Wide lens. Depending on the
`distance to the object, with the Tele lens focused on a
`subject of the photo, the Wide lens can be focused to a
`closer distance than the subject so that objects behind the
`subject appear very blurry. Once the two images are
`captured, information from the out-of-focus blurred
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`background in the Wide image is fused with the original
`Tele image background information, providing a blurrier
`background and even shallower DOF.
`
`Id., 4:23-38.
`
`The system and method presented in the ’479 Patent, namely, a dual-
`
`aperture camera system having 1) Wide and Tele lens systems with overlapping
`
`fields of view, and 2) a camera controller that performs image processing to
`
`calculate depth information and to fuse Wide and Tele images to emphasize the
`
`foreground and blur the background, were well known in the prior art prior to the
`
`’479 Patent. APPL-1003, ¶27.
`
`Prosecution History and Priority Date
`B.
`U.S. Patent Application No. 16/048,242 (“the ’242 App”) that issued as the
`
`’479 Patent was filed on July 28, 2018 and claims priority through a chain of
`
`applications to a provisional filed on June 13, 2013. APPL-1001, 1:5-20. The ’242
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`application was filed with 40 claims that ultimately issued as claims 1-40 in the
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`’479 Patent. See APPL-1002, p.334-66. The ’479 Patent issued on March 5, 2019.
`
`In the Notice of Allowance, the Examiner’s reasoning simply copied the
`
`limitations that were found to be patentable including “the Tele lens has a
`
`respective effective focal length EFLT and total track length TTLT fulfilling the
`
`condition EFLT / TTLT > 1. This limitation was known in the prior art.
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`V. LEVEL OF ORDINARY SKILL IN THE ART
`The level of ordinary skill in the art may be reflected by the prior art of
`
`record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001). Here, a
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`Person of Ordinary Skill in the Art (“POSITA”) at the time of the claimed
`
`invention would have a bachelor’s or the equivalent degree in electrical and/or
`
`computer engineering or a related field and 2-3 years of experience in imaging
`
`systems including optics and image processing. APPL-1003, ¶13. A POSITA also
`
`would have had experience in lens system design including analyzing, tolerancing,
`
`adjusting, and optimizing multi-lens systems with lens design software, and would
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`have been familiar with the specifications of lens systems including image sensors.
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`Id. Furthermore, a person with less formal education but more experience, or more
`
`formal education but less experience, could have also met the relevant standard for
`
`a POSITA. Id. However, Petitioner does not imply that a person having an
`
`extraordinary level of skill should be regarded as a POSITA.
`
`VI. CLAIM CONSTRUCTION
`The challenged claims of the ’479 Patent are construed herein “using the
`
`same claim construction standard that would be used to construe the claim in a
`
`civil action under 35 U.S.C. § 282(b).” 37 C.F.R. § 42.100(b) (Nov. 13, 2018). The
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`claim terms construed below are thus construed “in accordance with the ordinary
`
`and customary meaning of such claim as understood by one of ordinary skill in the
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`art and the prosecution history pertaining to the patent.” Id. For terms not
`
`addressed below, Petitioner submits that no specific construction is necessary for
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`this proceeding.
`
`A.
`
`“to find translations between matching points in the images to
`calculate depth information and to create a fused image suited for
`portrait photos” (claim 19).
`This term is recited in claim 19, where it appears as follows:
`
`e) a camera controller operatively coupled to the first and
`second AF mechanisms and to the Wide and Tele image
`sensors and configured to control the AF mechanisms, to
`process the Wide and Tele images to find translations
`between matching points in the images to calculate depth
`information and to create a fused image suited for portrait
`photos, the fused image having a DOF shallower than
`DOFT and having a blurred background.
`
`APPL-1001, 15:25-32.
`
`This limitation should be construed as requiring the “camera controller” to
`
`perform two separate functions: (1) “to find translations between matching point in
`
`the images to calculate depth information” and (2) “to create a fused image suited
`
`for portrait photos.”
`
`Regarding the operation “to find translations between matching point in the
`
`images to calculate depth information,” the specification references Fig. 6 which is
`
`“a method disclosed herein for acquiring a zoom image in video/preview mode for
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`3 different zoom factor (ZF) ranges.” Id., 11:30-32. As discussed above, the
`
`specification describes obtaining two images where, for a given ROI (“Region of
`
`Interest”) depth information is obtained for faster focusing:
`
`[R]egistration is performed between the Wide and Tele
`images to output a transformation coefficient. The
`transformation coefficient is used to set an AF position.
`The transformation coefficient includes the translation
`between matching points in the two images. This
`translation can be measured in a number of pixels.
`Different translations will result in a different number of
`pixel movements between matching points in the images.
`This movement can be translated into depth and the depth
`can be translated into an AF position. This enables to set
`the AF position by only analyzing two images (Wide &
`Tele). The result is fast focusing.
`
`Id., 12:7-15. Nowhere does the specification describe using the “translations
`
`between matching point” to “create a fused image suited for portrait photos.”
`
`APPL-1003, ¶33.
`
`Rather, the specification describes image fusion in relation to a different
`
`“Still Mode Operation” (shown in Fig. 2). See id., 7:44. In this separate
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`embodiment, “the obtained image is fused from information obtained by both sub-
`
`cameras at all zoom levels (see FIG. 2), which shows a Wide sensor 202 and a Tele
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`sensor 204 and their respective FOVs.” Id., 7:45-48. Fusing the Wide and Tele
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`images is stated to “achieve optical zoom, improves SNR and provides wide
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`dynamic range.” Id., 7:57-59. Nowhere does the specification describe fusing two
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`images using “translations between matching points.” APPL-1003, ¶34.
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`Based on these teachings and descriptions, a POSITA would have
`
`understood “to find translations between matching points in the images to calculate
`
`depth information and to create a fused image suited for portrait photos” as
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`requiring the claimed camera controller to perform two separate and independent
`
`operations: (1) “finding translations between matching points in the images to
`
`calculate depth information” and (2) “creating a fused image suited for portrait
`
`photos.” APPL-1003, ¶35.
`
`VII. REQUESTED RELIEF
`Petitioner requests that the Board institute inter partes review of claims 19-
`
`22 of the ’479 Patent and cancel each of those claims as unpatentable.
`
`VIII. OVERVIEW OF CHALLENGES
`A. Challenged Claims
`Claims 19-22 of the ’479 Patent are challenged.
`
`B.
`
`Statutory Grounds for Challenges
`
`Ground
`
`Claims
`
`19-20
`
`21-22
`
`1
`
`2
`
`
`
`Basis
`Obvious under § 103 over Parulski, Ogata,
`Kawamura, and Soga
`
`Obvious under § 103 over Parulski, Ogata,
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`Kawamura, Soga, and Morgan-Mar
`
`
`Parulski (APPL-1005) issued on December 28, 2010, Ogata (APPL-1026)
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`issued on August 13, 1996, Kawamura (APPL-1012) published on April 14, 1983,
`
`and Soga (APPL-1006) published on October 4, 2007, and are all prior art under
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`35 U.S.C. § 102(a)(1).
`
`Morgan-Mar (APPL-1009) was filed on November 13, 2013 and claims
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`priority to AU Patent Application No. 2012258467 filed December 3, 2012.
`
`According to Morgan-Mar’s file history (APPL-1008), the application was filed in
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`English (see id., pp.173-234) and a certified copy of the foreign application was
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`received by the Patent Office (see id., pp.48-108). Morgan-Mar is therefore prior
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`art under 35 U.S.C. § 102(a)(2) as of its AU filing date.
`
`C. Discretionary Denial is Not Warranted
`The Board should not exercise its discretion under 35 U.S.C. §§ 314(a) or
`
`325(d) to deny this Petition. Among other factors, none of the asserted prior art
`
`was cited during examination, and as the Examiner raised no arguments during
`
`prosecution, there is no “overlap between the arguments made during examination
`
`and the manner in which Petitioner relies on the prior art.” Becton, Dickinson and
`
`Company v. B. Braun Melsungen AG, IPR2017-01586, Paper 8 at 17–18 (PTAB
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`Dec. 15, 2017) (precedential). Further, the ’479 Patent has not been challenged in
`
`any prior IPR petition. None of discretionary institution factors 1–5 in General
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`IPR2020-00906 Petition
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`Inter Partes Review of 10,225,479
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`Plastic apply to this Petition. See General Plastic Indus. Co., Ltd. v. Canon
`
`Kabushiki Kaisha, IPR2016-01357, Paper 19 at 16 (PTAB Sept. 6, 2016) (Section
`
`II.B.4.i. precedential).
`
`Page Citations and Emphasis
`D.
`For exhibits that include suitable page, column, or paragraph numbers in
`
`their original publication, Petitioner’s citations are to those original numbers and
`
`not to the page numbers added for compliance with 37 CFR 42.63(d)(2)(ii). The
`
`Petition may bold or italicize quotations and add color or colored annotations to
`
`figures from exhibits for emphasis.
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`IX.
`
`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`A. Ground 1: Claims 19 and 20 are obvious over the combination of
`Parulski, Ogata, Kawamura, and Soga.
`Summary of Parulski
`1.
`U.S. Patent No. 7,859,588 to Parulski, et al. (“Parulski”) was filed on March
`
`9, 2007 and issued on December 28, 2010. See APPL-1005. Parulski is titled
`
`“Method and Apparatus for Operating a Dual Lens Camera to Augment an Image,”
`
`and discloses “a digital camera that uses multiple lenses and image sensors to
`
`provide an improved imaging capability.” Id., 1:8-10.
`
`Parulski describes several embodiments that can utilize its dual-capture
`
`enhancement methods. Id., 12:55-13:20. An example of the camera embodiment is
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`below:
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`Id., Figs. 2A-2B. Parulski describes this embodiment as an “image capture
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`assembly l0A” that includes “first zoom lens 3” and a “second zoom lens 4.” Id.,
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`12:55-59. The camera also includes “a color LCD image display 70 and a number
`
`of user controls 42, including a shutter button 42a for enabling an image capture
`
`sequence ….” Id., 12:60-62.
`
`In this camera embodiment, “[t]he optical axes of the zoom lenses 3 and 4
`
`and the sensors 12 and 14 are generally aligned with respect to each other so as to
`
`be viewing substantially the same scene, albeit typically with different fields of
`
`view.” Id., 13:6-9. An extended zoom range is provided by “digital zooming
`
`between the wide angle and the telephoto focal lengths.” Id., 23:54-58. As an
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`alternative, Parulski states that “one (or both) of the zoom lenses 3 and 4 could
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`be replaced with a fixed focal length lens.” Id., 13:4-6. Reference herein to
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`“Parulski’s camera” is to the embodiment that includes fixed-focal-length wide and
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`telephoto lenses.
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`Parulski teaches that its camera embodiment may operate in still and video
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`modes to produce “still images and motion video images.” Id., 12:36-41; see also
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`id., 14:5-9 (“The digital data ... is ... processed by the image processor 50 to
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`produce a processed digital image file, which may contain a still digital image or a
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`video image.”); Id., 29:8-11 (“the images captured by the primary and secondary
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`capture units could be a still image or a video image, and in the case of a video
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`image could be a series of images.”).
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`Parulski also describes several digital zoom features for its camera based on
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`a requested zoom position from a user that determines the primary image and
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`secondary image from two capture units of the digital camera based on the user
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`requested zoom position. Id., FIG. 23, 27:8-24, 29:51-64. If the requested zoom
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`position is less than a zoom switch value X, the first image station with a wide lens
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`is set as primary capture unit for providing a primary image, and the second image
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`station with a tele lens is set as a secondary capture unit for providing a secondary
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`image. Id., Figs. 3, 14, 23, 22:18-21 (“In block 502, the zoom position setting is
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`compared to a value X at which the image capture function switches” between
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`first/second image capture units), 15:54-61 (“In block 102, the zoom position
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`setting is compared to a value X at which the image capture function switches from
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`the first image capture stage to the second image capture stage. In block 104, if the
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`zoom position setting is less than X (a negative response to block 102), then the
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`first image capture stage 1 is used [as the primary image capture stage]”), 27:8-15
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`(if the requested zoom position is not within the zoom range of the current primary
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`capture unit for providing a primary image, “the functions of the capture units are
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`reversed,” where the current scene analysis unit for providing a secondary image
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`and the current primary capture unit for providing the primary image are “reset to
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`be the primary capture unit and scene analysis capture unit, respectively.”).
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`Parulski also teaches several image enhancement processes performed using
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`the primary and secondary images. First, as shown in Fig. 11, Parulski teaches that
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`a range map (i.e., depth map) can be created using the two images by correlating
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`the secondary image with a “cropped and upsampled [primary] image to
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`determine the pixel offset between the images for different portions of the
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`images.” Id., 20:9-11. The pixel offset information produces a “disparity map”
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`(i.e., a registration map) of pixel offset information, that is in turn used to produce
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`a range map or depth map. See id., 19:55-58 (“a method for producing a rangemap
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`or depth map from a disparity map produced from the pixel offset information for a
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`set of images captured by multiple cameras with similar fields of view”). The pixel
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`offsets are “converted in block 482 to distances from the image capture device
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`using the autofocus rangefinder calibration curve. A map is then produced in
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`block 484 showing the distances to different portions of the images.” Id., 20:11-
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`15. Parulski’s Fig. 11 showing its depth map creation process is below:
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`Id., Fig. 11.
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`Second, Parulski teaches image enhancement techniques by using an image
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`from one of the lens systems to enhance the image from the other lens system. This
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`is discussed in regard to Figure 14:
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` [I]n block 514, the secondary still image is used to
`enhance the depth of field of the primary image, for
`instance, where the secondary still image is used to
`provide an enhancement signal that can be used to
`sharpen portions of the primary still image that are
`positioned near the secondary focus distance.
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`Id., 22:37-45. This process is further discussed later in Parulski where one way of
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`sharpening portions of the primary image positioned near the secondary focus
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`distance is to fuse those focused portions of the secondary image with the
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`corresponding portions of the primary image. Id., 28:47-53 (“Then, the two images
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`are combined into a modified image with a broadened depth of field.”).
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`In sum, Parulski teaches a dual-lens camera system for capturing primary
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`and secondary images at different focal lengths with overlapping fields of view
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`(FOVs) and then processing the images (1) to create a depth map and (2) to create
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`an enhanced image using portion of images from both lens systems. APPL-1003,
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`¶43.
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`Summary of Kawamura
`2.
`Kawamura is titled “Telephoto Lens” and describes a “telephoto lens of a four-
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`group, five-lens configuration.” APPL-1012, p.1. Kawamura’s telephoto lens system
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`is designed to “provide a lens that keeps a compactness of an overall length to a
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`conventional level of a telephoto ratio of about 0.96 to 0.88” and “has an excellent
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`image-formation performance due to favorably correcting spherical aberration of
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`both a reference wavelength and color” while “decreasing chromatic aberration in
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`magnification.” Id.
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`Kawamura provides several embodiments (Examples 1-4) that each include
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`five lens elements. See id., p.1, Figs. 1, 3, 6, 8. In each embodiment, the telephoto
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`lens system includes a four-group, five-lens configuration including:
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`in order from an object side, a first lens, which is a positive
`meniscus lens that is convex toward the object side; a
`second lens and a third lens, which are a laminated positive
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`meniscus lens of a negative meniscus lens and positive
`meniscus lens having a lamination surface that is convex
`toward the object side; a fourth lens, which is a negative
`lens having a rear surface with a large curvature that is
`concave toward an image-surface side; and a fifth lens,
`which is a positive lens.
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`Id.
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`For Examples 1-4, Kawamura provides figures and a prescription table
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`including numerical values for the design. As an example, FIG. 1 and corresponding
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`table of example 1 are reproduced below:
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`APPL-1003, ¶46; APPL-1012, Fig. 1 (annotated).
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`APPL-1003, ¶46; APPL-1012, p.3 (Table for Example 1) (annotated).
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`While Kawamura was originally described as a 150-200 mm focal length
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`(see APPL-1012, p.1), a POSITA would have recognized that, given the
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`prescription data above, the design could have been scaled to work in a smaller
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`format such as to support digital image sensors that were more modern than when
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`Kawamura published in 1983. See APPL-1021, ¶43; APPL-1020, p.57. According
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`to Smith: “A lens prescription can be scaled to any desired focal length simply by
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`multiplying all of its dimensions by the same constant.” APPL-1026, p.57.
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`Based on Smith and as shown in Dr. Sasián’s declaration, a POSITA would
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`have recognized that Kawamura could be successfully scaled for a 1/2.5” image
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`sensor, as would have been compatible with image sensors that Parulski would
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`have considered for use in its camera embodiments. APPL-1021, ¶44; see APPL-
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`1005, 5:21-35 (indicating that the Kodak Easyshare V610 is a similar prior art
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`camera); APPL-1033, p.62 (indicating a 1/2.5” CCD image sensor in the V610
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`camera), APPL-1030 (specification sheet for a prior art 1/2.5” CCD sensor);
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`APPL-1029 (specification sheet for a prior art 1/2.5” CCD sensor).
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`Kawamura scaled in this way would have maintained the same field of view
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`(FOVW) of 24.3 degrees and f-number of 4.0 but would have had a lower focal
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`length (EFL) of 16.33 mm and total track length (TTL) of 15.343 mm as a result of
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`the scaling. APPL-1021, ¶45. A POSITA would have recognized that this could
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`have been done in lens design software such as Zemax, as indicated in the model
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`of Kawamura Example 1 scaled to support a 1/2.5” mm sensor, shown below:
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`Id.; see APPL-1022, pp.254-55.
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`Reasons to combine Parulski and Kawamura
`3.
`A POSITA would have combined Kawamura’s telephoto lens assembly with
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`Parulski’s fixed-focal-length camera embodiments