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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`ELECTRONICS AND TELECOMMUNICATIONS RESEARCH INSTITUTE
`Patent Owner
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`IPR2021-00827
`Patent 9,781,448
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`DECLARATION OF DR. IMMANUEL FREEDMAN
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`IPR2021-00827
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`Table of Contents
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`I. Background and Qualifications ...................................................................... 3
`II. Legal Framework .......................................................................................... 10
`A. Obviousness ....................................................................................................................... 10
`B. Claim Construction ............................................................................................................ 17
`III. OPINION ........................................................................................................ 17
`A. Level of Skill of a Person Having Ordinary Skill in the Art ............................................. 17
`B. Background of the Technology ......................................................................................... 19
`i.
`Background of Video Processing .............................................................................. 19
`ii.
`Video Encoding and Decoding .................................................................................. 25
`C. Obvious in view of Moon .................................................................................................. 29
`i.
`Overview of Moon ..................................................................................................... 29
`ii.
`Overview of Teng ...................................................................................................... 32
`iii.
`Overview of Wilkins ................................................................................................. 33
`iv. Motivations to Combine Moon, Teng, and Wilkins .................................................. 35
`v.
`Motivations to Combine Moon and Teng .................................................................. 46
`IV. Conclusion ...................................................................................................... 51
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
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`I, Dr. Immanuel Freedman, hereby declare the following:
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`I.
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`BACKGROUND AND QUALIFICATIONS
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`1. My name is Immanuel Freedman, and I am over 21 years of age and
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`otherwise competent to make this Declaration. I make this Declaration based on facts
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`and matters within my own knowledge and on information provided to me by others,
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`and, if called as a witness, I could and would competently testify to the matters set
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`forth herein.
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`2.
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`I have been retained as a technical expert witness in this matter by
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`Counsel for the Petitioner, Unified Patents, LLC (“Petitioner”) to provide my
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`independent opinions on certain issues requested by Counsel for Petitioner relating
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`to the accompanying Petition for Inter Partes Review of U.S. Patent No. 9,781,448
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`(“the ’448 patent”). My compensation in this matter is not based on the substance of
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`my opinions or on the outcome of this matter. I have been informed that GE Video
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`Compression, LLC is the purported owner of the ’448 patent. I note that I have no
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`financial interest in GE Video Compression, LLC, or Petitioner, and I have no other
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`interest in the outcome of this matter.
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`3.
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`I have over 30 years of industry experience, including a substantial
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`portion of which was spent working with image and video coding and developing
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`models and simulations to analyze various video and imaging systems. I have
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`summarized in this section my educational background, career history, and other
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`qualifications relevant to this matter. I have also included a current version of my
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`curriculum vitae as Exhibit 1007.
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`A. Education
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`4.
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`I earned a Bachelor of Science degree in Physics from the University
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`of Durham, England, in 1979. I obtained a Doctorate in Physics from the University
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`of Physics from the University of Durham, England in 1986. Between obtaining my
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`undergraduate and Doctorate degree, I developed a microcomputer system for
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`detecting coalmine fires and heatings as a scientist for the National Coal Board and
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`worked as a software engineer for Laser-Scan Ltd. in Cambridge, England.
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`B. Career Synopsis
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`5.
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`After obtaining my Doctorate, I served as a Research Assistant at
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`University College London from September 1986 to June 1987, where I developed
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`digital image processing algorithms to improve image and stereo-matching quality
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`for a digital terrain modeling system, including software and algorithms for affine
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`transformation, edge filtering, kriging interpolation, and image stereo-matching with
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`sub-pixel acuity. I continued my work with digital image processing as a Research
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`Associate at the University of Maryland, from June 1987 to September 1988. During
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`my time at the University of Maryland, I designed algorithms for filtering,
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`segmenting, clustering, and path planning based on digital images organized by
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`quad-tree data structures.
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`From September 1988 to June 1994, I worked as a Senior Systems
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`6.
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`Engineer for the Hughes STX Corporation. As part of my work, I developed methods
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`for comparison of sky maps from the Cosmic Background Explorer (COBE) mission
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`with sky maps from other missions based on scientific data stored in a spatially-
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`referenced database using a quad-tree data structure. In this role, I led the Systems
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`Engineering and end-to-end development of a novel system for compressing
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`imaging and ancillary data that combined scientific modeling with statistical data
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`compression. I was also charged with designing and developing evaluation tools to
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`ensure user-transparent, system-wide compression of a 380-GB dynamic database at
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`an image quality acceptable to end-user scientists. In recognition of my work, I
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`received a Hughes STX Achievement Award in 1990 and 1992.
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`7.
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`After June 1994, I began a six-month stint as a contract Software
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`Engineer for the Federal National Mortgage Association in Washington D.C., for
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`which I developed a graphical user interface to monitor and validate loan servicer
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`input for a Loss Mitigation Project. I then served as an Independent Consultant to
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`Optivision, Inc. for the next six months, where I researched and developed rate
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`control algorithms and software based on the MPEG-2 Test Model 5 for the
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`OPTIVideoÔ MPEG-2 video encoder, as well as adaptive quantization algorithms
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`based on the then-JPEG-3 draft standard. In this role, I researched and developed
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`algorithms to improve the quality of gray scale image compression for the medical
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`imaging DICOM Standard by providing a lossless hybrid algorithm encoding image
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`residuals with a diagonal Golomb code based an Enhanced Universal Trellis Coded
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`Quantization algorithm.
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`8.
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`Between December 1995 and March 1996, I served as a Senior Staff
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`Engineer/Firmware Engineer for General Instrument Inc., Comstream Inc., and
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`Armor Safe Technologies Inc. At Comstream, I worked on integrating an MPEG-2
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`set top box with OpenTV interactive television middleware programmed in the
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`Microtec C language ported to a Motorola 68340 processor under the pSOS
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`operating system.
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`9.
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`From January 1996-97, I was a sole proprietor of Anugraha, where I
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`researched and developed algorithms and processes to compress fine art
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`photography at an image quality acceptable to artists based on the JPEG imaging
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`standard implemented with image pre-processing and adaptive quantization. For the
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`next year or so, I worked as an engineering contractor or consultant for various
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`companies, working primarily on image processing systems and digital interactive
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`television set-top boxes.
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`10.
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`In October 1998, I began a six-month engagement with Rockwell
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`Collins Inc., where I worked as a Lead Systems Engineer tasked with harmonizing
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`requirements for an MPEG-2 in-flight entertainment system. I then worked for Sun
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`Microsystems Inc. as a Software Engineer until November 1999. During my time at
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`Sun Microsystems Inc., I developed a Distributed Component Object Model
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`(DCOM) software interface between a TV control graphical user interface and a
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`Microsoft broadcast application programming interface (API) with the goal of
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`improving the visual quality of interactive TV displays derived from UDP/IP
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`datagrams synchronized with MPEG-2 audio/video packet data.
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`11. For the next 22 months, from January 2000 to October 2002, I worked
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`as the Chief Systems Engineer for Media Logic Systems Ltd. During my time at
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`Media Logic Systems, I designed and developed a live interactive television system
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`(iSeeTV) in which customers communicate with human sales agents in video-
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`enabled call centers. To create this system, I researched and developed tools and
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`encoder systems to improve image quality at prescribed latency and bit rate for
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`distributing live video and audio streams encoded via low latency methods. To
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`perform the above, I was required to understand and implement video codec systems
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`employing the MPEG-2 Simple Profile at Main Level (CATV), MPEG-4 Visual
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`Profile with background sprite coding, and the H.263+ Standard (now known as
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`H.264).
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`12. Since November 2002, I have been an engineering contractor, and more
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`recently an independent consultant in mathematical modeling, for several
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`companies, such as Cyra Technologies Inc. and Amgen Inc. I also served as a senior
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`research fellow at Merck & Co., Inc., a manager at GlaxoSmithKline Inc. and,
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`currently serve as a director at Daiichi Sankyo, Inc. During this time, I have
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`developed mathematical models and simulations related to various systems, signals,
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`and images. Specifically, I have focused on analyzing, processing, storing, and
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`deriving information from biomedical imaging and other data. Using the information
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`derived from these data, I have created a variety of models related to biology and the
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`effects of drugs on the human body. In recognition of my work, I have received
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`GlaxoSmithKline R&D Recognition Awards in 2012, 2013, and 2016.
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`13.
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`In addition to my over thirty years of relevant industry experience, I
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`have authored many publications relating to video and imaging coding. In 2003, I
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`authored a chapter entitled “Video Compression” for the Internet Encyclopedia. In
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`2004 I authored the chapter entitled “Video” for the Berkshire Encyclopedia of
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`Human-Computer Interaction. And in 2007 I authored a chapter titled “Video
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`Compression” for the Handbook of Computer Networks.
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`14.
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`I am also a Senior Member of the Institute of Electrical and
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`Electronics Engineers (“IEEE”) and currently chair the Philadelphia Chapter of the
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`Communications & Information Theory Societies. I am the Past Chair of the
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`American Association of Pharmaceutical Scientists Pharmaco-Imaging and
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`currently chair the Predictive Modeling Community. I also served as the 2019 Vice
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`Chair of the IEEE P2673 Intelligence Augmentation for Medical Imaging
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`Standards Working Group and currently chair the Data Models Sub-Group of the
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`IEEE P2795 Shared Analytics for Secured and Unsecured Networks Standards
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`Working Group and recently served as Secretary for the IEEE Dynamic Spectrum
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`Access Standards Machine Learning Study Group. I also have been registered to
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`practice as a patent agent for the United States Patent and Trademark Office since
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`2002 (Reg. No. 51,704).
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`15. From 2017-2020, I also volunteered as a Research Scholar with the
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`State University of New York at Buffalo. In this role, I provided mentorship for a
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`doctoral candidate in areas relating to computer modeling and estimation.
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`16. As part of my work and in forming my opinions in connection with this
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`proceeding, I have reviewed the following materials, each of which I believe experts
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`in my field would reasonably rely upon in forming opinions regarding the subject
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`matter of this proceeding:
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`• U.S. Patent 9,781,448 (Ex. 1001);
`• File History for U.S. Patent 9,781,448 (Ex. 1002);
`• U.S. Pat. Pub. 2005/0201633 to Moon et al. (“Moon”) (Ex. 1004)
`• U.S. Pat. 8,681,867 to Teng et al. (“Teng”) (Ex. 1005)
`• U.S. Pat. 8,326,075 to Wilkins et al. (“Wilkins”) (Ex. 1006)
`• Shi et al., Image and Video Compression for Multimedia Engineering,
`CRC Press (2000) (“Shi”) (Ex. 1008)
`• Iain E. G. Richardson, H.264 and MPEG-4 Video Compression, John
`Wiley & Sons Ltd. (2003) (“Richardson”) (Ex. 1009)
`• Peter Symes, Video Compression Demystified, McGraw-Hill (2001)
`(“Symes”) (Ex. 1010)
`• IEEE Transactions on Circuits and Systems for Video Technology,
`Overview of the H.264/AVC Video Coding Standard, by Wiegand et al.
`(2003) (“Wiegand”) (Ex. 1013)
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
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`II. LEGAL FRAMEWORK
`A. Obviousness
`17.
`I am a technical expert and do not offer any legal opinions. However, I
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`have been informed about certain legal principles regarding patentability and related
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`matters under United States patent law, which I have applied in performing my
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`analysis and arriving at my technical opinions in this matter.
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`18.
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`I have been informed that a person cannot obtain a patent on an
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`invention if the differences between the invention and the prior art are such that the
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`subject matter as a whole would have been obvious at the time the invention was
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`made to a person having ordinary skill in the art (“PHOSITA”). I have been informed
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`that a conclusion of obviousness may be founded upon more than a single item of
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`prior art. I have been further informed that obviousness is determined by evaluating
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`the following factors: (1) the scope and content of the prior art, (2) the differences
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`between the prior art and the claim at issue, (3) the level of ordinary skill in the
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`pertinent art, and (4) secondary considerations of non-obviousness. In addition, the
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`obviousness inquiry should not be done in hindsight. Instead, the obviousness
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`inquiry should be done through the eyes of a PHOSITA at the time of the alleged
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`invention.
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`19.
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`In considering whether certain prior art renders a particular patent claim
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`IPR2021-00827 Freedman Declaration
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`obvious, I have been informed that I can consider the scope and content of the prior
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`art, including the fact that one of skill in the art would regularly look to the
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`disclosures in patents, trade publications, journal articles, conference papers,
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`industry standards, product
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`literature and documentation,
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`texts describing
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`competitive technologies, requests for comment published by standard setting
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`organizations, and materials from industry conferences, as examples. I have been
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`informed that for a prior art reference to be proper for use in an obviousness analysis,
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`the reference must be “analogous art” to the claimed invention. I have been informed
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`that a reference is analogous art to the claimed invention if: (1) the reference is from
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`the same field of endeavor as the claimed invention (even if it addresses a different
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`problem); or (2) the reference is reasonably pertinent to the problem faced by the
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`inventor (even if it is not in the same field of endeavor as the claimed invention). In
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`order for a reference to be “reasonably pertinent” to the problem, it must logically
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`have commended itself to an inventor's attention in considering his problem. In
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`determining whether a reference is reasonably pertinent, one should consider the
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`problem faced by the inventor, as reflected either explicitly or implicitly, in the
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`specification. I believe that all of the references I considered in forming my opinions
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`in this IPR are well within the range of references a PHOSITA would have consulted
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`to address the type of problems described in the Challenged Claims.
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`I have been informed that, in order to establish that a claimed invention
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`20.
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`was obvious based on a combination of prior art elements, a clear articulation of the
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`reason(s) why a claimed invention would have been obvious must be provided.
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`Specifically, I am informed that, under the U.S. Supreme Court’s KSR decision, a
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`combination of multiple items of prior art renders a patent claim obvious when there
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`was an apparent reason for one of ordinary skill in the art, at the time of the invention,
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`to combine the prior art, which can include, but is not limited to, any of the following
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`rationales: (A) combining prior art methods according to known methods to yield
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`predictable results; (B) substituting one known element for another to obtain
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`predictable results; (C) using a known technique to improve a similar device in the
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`same way; (D) applying a known technique to a known device ready for
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`improvement to yield predictable results; (E) trying a finite number of identified,
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`predictable potential solutions, with a reasonable expectation of success; (F)
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`identifying that known work in one field of endeavor may prompt variations of it for
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`use in 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 one of ordinary skill in the art; or
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`(G) identifying an explicit teaching, suggestion, or motivation in the prior art that
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`would have led one of ordinary skill to modify the prior art reference or to combine
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`the prior art references to arrive at the claimed invention. I am also informed that
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`where there is a motivation to combine, claims may be rejected as prima facie
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`IPR2021-00827 Freedman Declaration
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`obvious provided a PHOSITA would have had a reasonable expectation of success
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`regarding the proposed combination.
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`21.
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`I am informed that the existence of an explicit teaching, suggestion, or
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`motivation to combine known elements of the prior art is a sufficient, but not a
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`necessary, condition to a finding of obviousness. This so-called “teaching-
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`suggestion-motivation” test is not the exclusive test and is not to be applied rigidly
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`in an obviousness analysis. In determining whether the subject matter of a patent
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`claim is obvious, neither the particular motivation nor the avowed purpose of the
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`patentee controls. Instead, the important consideration is the objective reach of the
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`claim. In other words, if the claim extends to what is obvious, then the claim is
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`invalid. I am further informed that the obviousness analysis often necessitates
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`consideration of the interrelated teachings of multiple patents, the effects of demands
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`known to the technological community or present in the marketplace, and the
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`background knowledge possessed by a person having ordinary skill in the art. All of
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`these issues may be considered to determine whether there was an apparent reason
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`to combine the known elements in the fashion claimed by the patent.
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`22.
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`I also am informed that in conducting an obviousness analysis, a precise
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`teaching directed to the specific subject matter of the challenged claim need not be
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`sought out because it is appropriate to take account of the inferences and creative
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`steps that a PHOSITA would employ. The prior art considered can be directed to
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`IPR2021-00827 Freedman Declaration
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`any need or problem known in the field of endeavor at the time of invention and can
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`provide a reason for combining the elements of the prior art in the manner claimed.
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`In other words, the prior art need not be directed towards solving the same specific
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`problem as the problem addressed by the patent. Further, the individual prior art
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`references themselves need not all be directed towards solving the same problem. I
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`am informed that, under the KSR obviousness standard, common sense is important
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`and should be considered. Common sense teaches that familiar items may have
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`obvious uses beyond their primary purposes.
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`23.
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`I also am informed that the fact that a particular combination of prior
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`art elements was “obvious to try” may indicate that the combination was obvious
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`even if no one attempted the combination. If the combination was obvious to try
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`(regardless of whether it was actually tried) or leads to anticipated success, then it is
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`likely the result of ordinary skill and common sense rather than innovation. I am
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`further informed that in many fields it may be that there is little discussion of obvious
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`techniques or combinations, and it often may be the case that market demand, rather
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`than scientific literature or knowledge, will drive the design of an invention. I am
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`informed that an invention that is a combination of prior art must do more than yield
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`predictable results to be non-obvious.
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`24.
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`I am informed that for a patent claim to be obvious, the claim must be
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`obvious to a PHOSITA at the time of the alleged invention. I am informed that the
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`factors to consider in determining the level of ordinary skill in the art include (1) the
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`educational level and experience of people working in the field at the time the
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`invention was made, (2) the types of problems faced in the art and the solutions
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`found to those problems, and (3) the sophistication of the technology in the field.
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`25.
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`I am informed that it is improper to combine references where the
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`references teach away from their combination. I am informed that a reference may
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`be said to teach away when a PHOSITA, upon reading the reference, would be
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`discouraged from following the path set out in the reference, or would be led in a
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`direction divergent from the path that was taken by the patent applicant. In general,
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`a reference will teach away if it suggests that the line of development flowing from
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`the reference’s disclosure is unlikely to be productive of the result sought by the
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`patentee. I am informed that a reference teaches away, for example, if (1) the
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`combination would produce a seemingly inoperative device, or (2) the references
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`leave the impression that the product would not have the property sought by the
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`patentee. I also am informed, however, that a reference does not teach away if it
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`merely expresses a general preference for an alternative invention but does not
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`criticize, discredit, or otherwise discourage investigation into the invention claimed.
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`26.
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`I am informed that even if a prima facie case of obviousness is
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`established, the final determination of obviousness must also consider “secondary
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`considerations” if presented. In most instances, the patentee raises these secondary
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`considerations of non-obviousness. In that context, the patentee argues an invention
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`would not have been obvious in view of these considerations, which include: (a)
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`commercial success of a product due to the merits of the claimed invention; (b) a
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`long-felt, but unsatisfied need for the invention; (c) failure of others to find the
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`solution provided by the claimed invention; (d) deliberate copying of the invention
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`by others; (e) unexpected results achieved by the invention; (f) praise of the
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`invention by others skilled in the art; (g) lack of independent simultaneous invention
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`within a comparatively short space of time; (h) teaching away from the invention in
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`the prior art.
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`27.
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` I am further informed that secondary-considerations evidence is only
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`relevant if the offering party establishes a connection, or nexus, between the
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`evidence and the claimed invention. The nexus cannot be based on prior art features.
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`For example, if commercial success of products allegedly embodying the claims is
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`presented as a secondary indicium of non-obviousness, the patent owner must show
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`that such success is due to features of the claimed invention, and not features
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`unrelated to the claimed invention or that already existed in the prior art. The
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`establishment of a nexus is a question of fact. While I understand that the Patent
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`Owner here has not offered any secondary considerations at this time, I will
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`supplement my opinions in the event that the Patent Owner raises secondary
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`considerations during the course of this proceeding.
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`B. Claim Construction
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`28.
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`I have been informed by counsel that the first step in an unpatentability
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`analysis involves construing the claims, as necessary, to determine their scope.
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`Second, the construed claim language is then compared to the disclosures of the prior
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`art. I am informed that claims are generally given their ordinary and custom meaning
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`as understood by one of ordinary skill in the art at the time of the invention, in light
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`of the patent specification.
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`29. For purposes of this proceeding, I have applied the meaning of the claim
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`terms of the ’448 Patent that is generally consistent with the terms’ ordinary and
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`customary meaning, as a person having ordinary skill in the art would have
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`understood them at the time of the invention. I have been instructed to assume for
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`purposes of this proceeding that the time of the claimed invention is April 9, 2010.
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`III. OPINION
`A. Level of Skill of a Person Having Ordinary Skill in the Art
`30.
`I was asked to provide my opinion as to the level of skill of a person
`
`having ordinary skill in the art (“PHOSITA”) of the ’448 Patent at the time of the
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`claimed invention, which I have been instructed to assume is April 9, 2010. In
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`determining the characteristics of a hypothetical person of ordinary skill in the art of
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`the ’448 Patent at the time of the claimed invention, I was told to consider several
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`factors, including the type of problems encountered in the art, the solutions to those
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`IPR2021-00827
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`Unified EX1003 Page 17
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`problems, the rapidity with which innovations are made in the field, the
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`sophistication of the technology, and the education level of active workers in the
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`field. I also placed myself back in the time frame of the claimed invention and
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`considered the colleagues with whom I had worked at that time.
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`31.
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`In my opinion, a person having ordinary skill in the art of the ’448
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`Patent at the time of its filing would have been a person having, as of April 9, 2010:
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`(1) at least an undergraduate degree in electrical engineering or computer
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`engineering or a closely related scientific field, such as physics or computer science,
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`or similar advanced post-graduate education in this area; (2) a working knowledge
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`of video coding techniques; and (3) two or more years of experience with video
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`processing. Such a person of ordinary skill in the art would have been capable of
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`understanding the ’448 Patent and the prior art references discussed herein.
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`32. Based on my education, training, and professional experience in the
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`field of the claimed invention, I am familiar with the level and abilities of a person
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`of ordinary skill in the art at the time of the claimed invention. Additionally, I met
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`at least these minimum qualifications to be a person having ordinary skill in the art
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`at least as of April 9, 2010. Further, although my qualifications may exceed those of
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`the hypothetical person having ordinary skill in the art defined above, my analysis
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`and opinions regarding the ’448 Patent have been rendered from the perspective of
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`a person having ordinary skill in the art at the time of the invention.
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`IPR2021-00827
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`Unified EX1003 Page 18
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
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`B.
`33.
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`Background of the Technology
`I was asked to briefly summarize the background of the prior art from
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`the standpoint of a PHOSITA prior to the assumed date of invention of April 9, 2010.
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`For the convenience of the reader, I refer to the Unified Exhibit page number located
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`at the lower right-hand side for any non-patent or patent-application reference cited
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`herein.
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`i.
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`Background of Video Processing
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`34. The ’448 Patent is in the field of video coding media content such as
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`video data, and applying filters during coding to improve image quality. ’448 Patent
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`at Abstract; 2:11-54; Claim 1. Digital video is formed from successive video frames
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`or images made up from an array of picture elements, or pixels.1 During playback,
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`the frames are successively displayed at a high enough frame rate such that the
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`transition between frames is imperceptible to the human eye to give an end user the
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`impression of continuous motion.2
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`35. Video files can be large due to the significant amount of image data
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`associated with each video frame in a sequence. To reduce the sizes and make the
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`transmission and storage of video more cost effective, video coding techniques are
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`used to compress, or encode, video files for efficient transmission and
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`1 See, e.g., Richardson (Ex. 1009) at 36-38.
`2 See id. at 36; see also id. at 46.
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`IPR2021-00827
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`Unified EX1003 Page 19
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
`decompression, or decoding, and output at an end-use display device. When the
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`video is compressed it is subdivided into “packets” for convenient transmission over
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`network protocols and other means of transmission. Various video coding standards
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`for compressing video have been introduced in an attempt to standardize video
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`coding. For example, in 1996, the International Organization for Standardization
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`(“ISO”) and the International Electrotechnical Commission (“IEC”) jointly adopted
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`part 2 of ISO/IEC 13818-2:1996, also known as the MPEG-2 standard. MPEG-2 was
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`an advance over prior video compression standards, including ISO/IEC 11172-
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`3:1993, also known as MPEG-1 and H.262. One common goal among these
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`encoding standards is to reduce the number of bits to communicate video data while
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`maintaining or improving the quality of video.
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`36. Compression of video data is achieved by eliminating redundancy in
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`video data.3 Specifically, within a particular sequence of video images, individual
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`frames can be correlated to benefit from redundant video information from within a
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`given frame (spatial correlation) and from successive frames captured at around the
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`same time (temporal correlation):
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`3 Id. at 52.
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`IPR2021-00827
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`Unified EX1003 Page 20
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`IPR2021-00827 Freedman Declaration
`U.S. Patent 9,781,448
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`
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`Richardson (Ex. 1009) at 53, Fig. 3.2. For example, in the above example, the front
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`frame depicts multiple areas where adjacent pixels will all be black due to the
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`lighting and hair color of the subjects—exploiting the spatial redundancy of these
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`proximate pixels will reduce the data needed to decode, or decompress and
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`reconstruct the image. And these two frames have a number of areas where the pixels
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`are very similar or identical, particularly in the background—exploiting the temporal
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`redundancies in the frames will also red
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