Apple Petition For Invalidation of Patent 9245314

UNITED STATES PATENT AND TRADEMARK OFFICE
———————
BEFORE THE PATENT TRIAL AND APPEAL BOARD
———————
APPLE INC.,
Petitioner,
v.
RED.COM, LLC,
Patent Owner
———————
PETITION FOR INTER PARTES REVIEW OF
U.S. PATENT NO. 9,245,314

Petition for Inter Partes Review of U.S. Patent No. 9,245,314
TABLE OF CONTENTS
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 .......................... 1
III. GROUNDS FOR STANDING ........................................................................2
IV. PAGE CITATIONS AND EMPHASIS ..........................................................2
V. THE ’314 PATENT .........................................................................................3
A. The ’314 patent is not entitled to its earliest effective filing date. ....... 3
VI. LEVEL OF ORDINARY SKILL IN THE ART .............................................6
VII. CLAIM CONSTRUCTION ............................................................................6
A. “Raw Mosaiced Image Data” ............................................................... 7
B. “Demosaiced Motion Video Data” ...................................................... 8
C. “Substantially Visually Lossless” ........................................................ 9
D. “the memory device is sufficiently large to store image data from

the compression module corresponding to at least about 30
minutes of video at 12 mega pixel resolution, 12-bit color
resolution, and at 60 frames per second.” ............................................ 9
VIII. RELIEF REQUESTED AND THE REASONS FOR THE

REQUESTED RELIEF .................................................................................10
IX. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE ....10
A. Challenged Claims ............................................................................. 10
ii
B. Statutory Grounds for Challenge........................................................ 10
C. Claims 1-10, 12-13, 15-26, and 28-29 are obvious over Presler in
view of Molgaard. .............................................................................. 12
1. Presler....................................................................................... 12
2. Molgaard .................................................................................. 16
3. Reasons to Combine ................................................................ 17
1. Claim 1 ..................................................................................... 17
2. Claim 2 ..................................................................................... 46
3. Claim 3 ..................................................................................... 47
4. Claim 4 ..................................................................................... 48
5. Claim 5 ..................................................................................... 49
6. Claim 6 ..................................................................................... 50
7. Claim 7 ..................................................................................... 51
8. Claim 8 ..................................................................................... 51
9. Claim 9 ..................................................................................... 53
10. Claim 10 ................................................................................... 54
11. Claim 12 ................................................................................... 54
12. Claim 13 ................................................................................... 55
13. Claim 15 ................................................................................... 57
14. Claim 16 ................................................................................... 57
15. Claim 17 ................................................................................... 61
16. Claim 18 ................................................................................... 61
iii
17. Claim 19 ................................................................................... 62
18. Claim 20 ................................................................................... 62
19. Claim 21 ................................................................................... 63
20. Claim 22 ................................................................................... 64
21. Claim 23 ................................................................................... 64
22. Claim 24 ................................................................................... 64
23. Claim 25 ................................................................................... 65
24. Claim 26 ................................................................................... 65
25. Claim 28 ................................................................................... 65
26. Claim 29 ................................................................................... 66
D. Claims 11 and 27 are obvious over Presler in view of Molgaard,

further in view of Sodini. ................................................................... 67
1. Sodini ....................................................................................... 67
3. Claim 11 ................................................................................... 68
4. Claim 27 ................................................................................... 69
E. Claims 14 and 30 are obvious over Presler in view of Molgaard,

further in view of Frost....................................................................... 70
1. Frost.......................................................................................... 70
3. Claim 14 ................................................................................... 71
4. Claim 30 ................................................................................... 72
iv
X. CONCLUSION..............................................................................................72
CERTIFICATE OF WORD COUNT ......................................................................73
CERTIFICATE OF SERVICE ................................................................................74
v
PETITIONER’S EXHIBIT LIST
May 6, 2019
Ex. 1001 U.S. Patent No. 9,245,314

Ex. 1002 Prosecution History of U.S. Patent No. 9,245,314
Ex. 1003 Declaration of Cliff Reader, Ph.D. under 37 C.F.R. § 1.68
Ex. 1004 Curriculum Vitae of Cliff Reader, Ph.D.
Ex. 1005 U.S. Patent No. 9,565,419 to Presler (“Presler”)
Ex. 1006 U.S. Patent No. 7,656,561 to Molgaard et al. (“Molgaard”)
Ning Zhang et al., “Lossless Compression of Color Mosaic
Ex. 1007 Images,” IEEE Transactions on Image Processing Vol. 15, No. 6
(June 2006) (“Zhang”)
Ben Long, REAL WORLD APERTURE, 1st Ed., ISBN: 0-321-44193-1
Ex. 1008
(July 11, 2006) (“Long”)
Serial ATA International Organization: Serial ATA Revision 2.6
Ex. 1009
(Feb. 15, 2007)
U.S. Provisional Application No. 60/911,196 (“The ’196
Ex. 1010
Application”)
U.S. Provisional Application No. 61/017,406 (“The ’406
Ex. 1011
Application”)
U.S. Provisional Application No. 60/923,339 (“the ’339
Ex. 1012
Application”)
Ex. 1013 U.S. Patent No. 7,349,574 to Sodini et al. (“Sodini”)
Ex. 1014 U.S. Patent No. 8,170,402 to Frost-Ruebling et al. (“Frost”)
Ex. 1015 Reserved
Ex. 1016 U.S. Patent No. 3,971,065 to Bayer (“Bayer”)
vi
I. INTRODUCTION
U.S. Patent No. 9,245,314 (“the ’314 patent,” Ex. 1001) is directed to “a
video camera” configured to “capture, compress, and store video image data in a
memory of the video camera.” Ex. 1001, Abstract. This Petition demonstrates that
claims are unpatentable under pre-AIA 35 U.S.C. § 103(a) and Petitioner, Apple
Inc., respectfully requests that these claims be canceled.
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 the
Petitioner, the ’314 patent has been asserted in Red.com, Inc. v. Sony Corp. of Am.,
Case No. 2:16-cv-00937-RSP (E.D. Tx. Aug. 24, 2016) and Red.com, Inc. v. Nokia
USA Inc., Case No. 8:16-cv-00594-MWF-JC (C.D. Ca. Mar. 30, 2016). Both cases
are terminated.
C. Lead and Back-up Counsel and Service Information
Lead Counsel
Michael S. Parsons Phone: (972) 739-8611
HAYNES AND BOONE, LLP Fax: (214) 200-0853
2323 Victory Ave. Suite 700 michael.parsons.ipr@haynesboone.com
Dallas, TX 75219 USPTO Reg. No. 58,767
Back-up Counsel
1
Andrew S. Ehmke Phone: (214) 651-5116

2323 Victory Ave. Suite 700 andy.ehmke.ipr@haynesboone.com
Jordan Maucotel Phone: (972) 739-8621

2323 Victory Ave. Suite 700 jordan.maucotel.ipr@haynesboone.com
Please address all correspondence to lead and back-up counsel. Petitioner
consents to electronic service via email.
III. GROUNDS FOR STANDING
Petitioner certifies that the ’314 patent is eligible for inter partes review and
that Petitioner is not barred or estopped from requesting inter partes review
challenging the claims on the grounds identified in this Petition. Petitioner has not
been served with a complaint asserting infringement of the ’314 patent and has not
filed a civil action challenging the validity of any claim.
IV. PAGE CITATIONS AND EMPHASIS
Petitioner’s citations to Exs. 1002 and 1007-1012 use the page numbers
added for compliance with 37 C.F.R. § 42.63(d)(2)(ii). Petitioner’s citations to the
remaining exhibits use the page numbers in their original publication. All bold
underline emphasis in any quoted material has been added.
2
V. THE ’314 PATENT
The ’314 patent is directed to “a video camera” configured to “capture,
compress, and store video image data in a memory of the video camera.” Ex. 1001,
Abstract.
A. The ’314 patent is not entitled to its earliest effective filing date.
The ’314 patent issued on January 26, 2016 from U.S Patent App. No.
14/485,612 (“the ’612 application”) filed on September 12, 2014. See Ex. 1001.
The ’612 application is a continuation of a string of applications that originate with
a continuation of U.S. Patent Application No. 12/101,882 (“the ’882 application”).
Id. The ’882 application claims priority to Provisional Application No. 61/017,406
(“the ’406 application”) filed on December 28, 2007 and Provisional Application
No. 60/911,196 (“the ’196 application”) filed on April 11, 2007. Id.
The ’196 application (the earliest provisional application) does not provide
§112 written description support for at least independent claims 1 and 16. The ’314
patent is therefore not entitled to the ’196 application’s filing date of April 11,
2007. See Dynamic Drinkware v. National Graphics, 800 F.3d 1375, 1380 (Fed.
Cir. 2015).
First, there is no presumption that the ’314 patent is entitled to its alleged
earliest filing date “because the PTO does not examine priority claims unless
necessary.” Id. Second, should Patent Owner defend its alleged priority date, such
3
defense fails because the ’196 application lacks written description support for at
least the limitation “output the raw mosaiced image data at a resolution of at least
2 k and at a frame rate of at least about 23 frames per second” in claims 1 and 16.
According to 35 U.S.C. § 119(e)(1), a patent claim receives the benefit of a
provisional application’s filing date only if the disclosure of the provisional
application provides §112 written description support for the patent claim. To
satisfy the written description requirement, the disclosure of the earlier-filed
application must “reasonably convey[] to those skilled in the art that the inventor
had possession of the claimed subject matter as of the filing date.” Ariad Pharm.,
Inc. v. Eli Lilly & Co., 598 F.3d 1336, 1351 (Fed. Cir. 2010) (en banc) (emphasis
added).
Here, there is no evidence that the inventors contemplated the specific
disclosure of “output[ting] the raw mosaiced image data at a resolution of at least 2
k and at a frame rate of at least about 23 frames per second.” Support for this is
completely absent from the ’196 provisional application. See Ex. 1010. Instead, the
’196 application describes decompression and demosaicing algorithms, but does
not disclose image resolution or frame rate parameters, let alone a camera system
capable of meeting such parameters. See id., pp.1-3. The first mention of any such
parameters appeared in the later ’406 provisional application filed about 8 months
later. See Ex. 1011, p.1. Accordingly, claims 1 and 16 (and therefore all claims) of
4
the ’314 patent are not fully supported by and therefor fail to receive the benefit of
the ’196 application’s April 11, 2007 filing date.
Moreover, to the extent that Patent Owner argues that any claimed resolution
and frame rate parameters are an obvious equivalent or variant of the equation
disclosed in the provisional application, the Federal Circuit has repeatedly held that
a disclosure in a parent application that merely renders obvious the claimed
invention is not sufficient to satisfy the written description requirement. See, e.g.,
Tronzo v. Biomet, Inc., 156 F.3d 1154, 1159 (Fed. Cir. 1998). Instead, the
description in a parent application must “actually or inherently disclose the claim
element.” PowerOasis, Inc. v. T-Mobile USA, Inc., 522 F.3d 1299, 1306-07 (Fed.
Cir. 2008). Here, the claimed resolution and frame rate parameters are not actually
or even inherently disclosed in the ’196 application. And, any evidence of a
POSITA’s knowledge provides no remedy. See Lockwood v. Am. Airlines, Inc.,
107 F.3d 1565, 1571-72 (Fed. Cir. 1997) (“Entitlement to a filing date does not
extend to subject matter which is not disclosed, but would be obvious over what is
expressly disclosed”).
Thus, because the ’196 application lacks adequate written description
support for each limitation of the ’314 patent, the claims do not receive the benefit
of the April 11, 2007 filing date.
5
VI. 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); In re
GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995). Here, a person of ordinary skill in
the art (“POSITA”) would include someone who had, at the priority date of the
’314 patent (i) a Bachelor’s degree in Computer Science, Electrical Engineering, or
equivalent training, as well as (ii) approximately three years of experience in
designing and/or manufacturing video capture, processing, and display systems.
Such a person would have also had experience in data compression. Ex. 1003,
pp.9-10.
VII. CLAIM CONSTRUCTION
This Petition presents claim analysis in a manner that is consistent with a
claim term’s plain and ordinary meaning in light of the specification. See 37 C.F.R.
§ 42.100(b). Accordingly, claim terms are given their ordinary and accustomed
meaning as would be understood by a person of ordinary skill in the art in the
context of the entire disclosure. In re Translogic Tech., Inc., 504 F.3d 1249, 1257
(Fed. Cir. 2007) (citing Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en
6
banc)). For terms not addressed below, Petitioner submits that no specific
construction is necessary for this proceeding. 1
A. “Raw Mosaiced Image Data”
This term is used in independent claims 1 and 16. The specification of the
’314 patent does not offer an express definition of “mosaiced” image data. Apart
from the claims and Abstract, the ’314 patent does not use the term “mosaic” or
“mosaiced,” and refers only to the terms “demosaic,” “demosaiced,” and
“demosaicing.” See e.g., Ex. 1001, 8:23-26, 10:25-27. The term “mosaiced,”
however, is well known in the art as evidenced by Long (Ex. 1008), which
describes “raw” data as received directly from a camera or similar device:
When you shoot in raw format … no demosaicing is performed by the

camera. Instead, the raw data that your image sensor captures is written
directly to your camera’s storage card. Demosaicing is then the
performed in your raw conversion software.
Ex. 1008, p.33. Long also describes the process of creating raw “mosaiced” data:
Each pixel on your camera’s sensor has a colored filter over it, usually
a red, green, or blue filter ... each pixel on the sensor is able to register
one primary color. To turn this mosaic of primary-color pixels into a
full-color image, a process called demosaicing is employed.
1
Petitioner does not concede that any term not construed herein meets the statutory
requirements of 35 U.S.C. § 112.
7
Ex. 1008, p.32. Zhang (Ex. 1007) also describes this process: “primary color
samples are interleaved in a two-dimensional (2-D) grid, or color mosaic,
resembling a three-color checkerboard.” Ex. 1007, p.1.
Accordingly, a POSITA would have understood the term “raw mosaiced
motion video image data” to include “motion video image data directly from a
camera’s image sensor, where each pixel represents one color.” Ex. 1003, p.19.
B. “Demosaiced Motion Video Data”
This term is used in independent claims 1 and 16. The specification of the
’314 patent does not offer an express definition of “demosaiced” data. However,
the ’314 patent discusses “demosaicing” in the context of adjusting image values:
“a downstream demosaicing/reconstruction component can selectively add green
image values back into the image data of the other colors.” Ex. 1001, 8:23-26.
Further, the ’314 patent discusses “demosaiced” image data in a full-color format:
“the monitor module 26 can output a demosaiced image data to the display 30 ...
the display 30 can be connected to the monitor module through any type of video
cables such as, for example, an RGB or YCC format video cable.” Ex. 1001,
10:27-39.
Accordingly, a POSITA would have understood the term “demosaiced
motion video data” to include “full-color motion video data reconstructed from
mosaiced motion video data.” Ex. 1003, p.20.
8
C. “Substantially Visually Lossless”
This term is recited in independent claims 1 and 16 and is generally used in
the context of comparing sets of image data. For example, the ’314 patent defines
the term “visually lossless”:
As used herein, the term “visually lossless” is intended to include

output that, when compared side by side with original (never
compressed) image data on the same display device, one of ordinary
skill in the art would not be able to determine which image is the
original with a reasonable degree of accuracy, based only on a visual
inspection of the images.
Ex. 1001, 9:55-60. Accordingly, a POSITA would have understood the term
“substantially visually lossless” to include “sets of data that are substantially
visually similar from the point of view of one of ordinary skill in the art.” Ex. 1003,
p.20.
D. “the memory device is sufficiently large to store image data from

the compression module corresponding to at least about 30
minutes of video at 12 mega pixel resolution, 12-bit color
resolution, and at 60 frames per second.”
This term is recited in claims 14 and 30. The’314 patent does not indicate
the capacity of the memory device sufficient to store image data according to this
term but such requirement can be calculated based on the minimum compression
ratio disclosed in the specification. Specifically, the specification teaches that its
camera system can “compress and store in the memory device the raw image data
9
at a compression ratio of at least six to one.” Ex. 1001, 1:53-55. A POSITA would
have thus recognized that 30 minutes of image data captured at 12 megapixel
resolution, at 12-bit color, at 60 fps, and compressed at a 6:1 ratio would have
required a total memory capacity of 324 gigabytes. Ex. 1003, p.21.
VIII. RELIEF REQUESTED AND THE REASONS FOR THE

REQUESTED RELIEF
Petitioner asks that the Board review the accompanying prior art and
analysis, institute a trial for inter partes review of claims 1-30 (all claims) of the
’314 patent and cancel these claims. As explained below, the concepts claimed in
the ’314 patent were not new. This Petition explains where each element of the
challenged claims is found in the prior art and why the challenged claims would
have been obvious before the earliest effective priority date of the ’314 patent.
IX. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
A. Challenged Claims
Claims 1-30 of the ’314 patent are challenged in this petition.
B. Statutory Grounds for Challenge
Claims 1-10, 12-13, 15-26, and 28-29 are unpatentable under pre-AIA 35
U.S.C. § 103(a) over U.S. Patent No. 9,565,419 to Presler (“Presler,” Ex. 1005) in
view of U.S. Patent No. 7,656,561 to Molgaard et al. (“Molgaard,” Ex. 1006).
Presler claims priority to a provisional application filed on April 13, 2007 and is
10
prior art to the ’314 patent under pre-AIA 35 U.S.C. § 102(e).2 Molgaard was filed
on June 14, 2004 and is prior art to the ’314 patent under pre-AIA 35 U.S.C. §
102(e).3
Claims 11 and 27 are unpatentable under pre-AIA 35 U.S.C. § 103(a) over
Presler in view of Molgaard, further in view of U.S. Patent No. 7,349,574 to Sodini
et al. (“Sodini,” Ex. 1013). Sodini was filed on October 14, 2003 and is prior art to
the ’314 patent under pre-AIA 35 U.S.C. § 102(e).
Claims 14 and 30 are unpatentable under pre-AIA 35 U.S.C. § 103(a) over
Presler in view of Molgaard, further in view of U.S. Patent No. 8,170,402 to Frost-
Ruebling et al. (“Frost,” Ex. 1014). Frost was filed on June 15, 2006 and is prior
art to the ’314 patent under pre-AIA 35 U.S.C. § 102(e).
2
As discussed above, the ’314 patent is not entitled to its April 11, 2007 priority
date, thus making Presler prior art by at least 8 months.

3
Molgaard also published as US2005/0276496 on December 15, 2005, which is
prior art to the ’314 patent under 35 U.S.C. § 102(b).
11
C. Claims 1-10, 12-13, 15-26, and 28-29 are obvious over Presler in
view of Molgaard.
1. Presler
Presler describes a “portable digital camera and recording system” that
records “high definition raw images at film or video rates for HD, 2K and 4K,
cinema quality production.” Ex. 1005, 4:35-36, 6:21-22.
Presler’s camera is shown in Figure 8 below:
Id., Fig. 8.
Presler claims and is entitled to the filing date of Provisional Application
No. 60/923,339 (“the ’339 Application”) filed on April 13, 2007. See id., 1:8-13;
12
Ex. 1012. In that regard, all elements of Presler’s independent claim 1 are
disclosed by the ’339 application, as shown in the table below:
U.S. 9,565,419 Support in Provisional Application (60/923,339)

(Presler) Claims
Claim 1
[1.0] A high definition “The disclosed invention describes a digital camera system
digital camera system that captures high definition raw images at film or video
comprising: rates.” Ex. 1012, p.3.
[1.1] an optical “The camera system uses optics to gather light from a
assembly for gathering desired scene to a pixilated sensor.” Ex. 1012, p.3.
light from a desired
scene,
[1.2] a modular “The modular imaging subsystem consists of an HD/2K or

imaging sub-system 4K CMOS imaging module and a frame grabber and
comprising an imager controller. One CMOS imaging module consists of an
including at least one Altasens 4562 2K and HD CMOS system-on-chip, Xilinx
array of pixels aligned FPGA, Microchip PIC micro controller, Linear LT series
with the optical Linear regulators, IDT ICS-307 programmable clock and
assembly, Fox 924 temperature-controlled crystal oscillator.” Ex.
1012, p.5.
Figure 2 of the ’339 application as annotated below also
shows this modular imaging sub-system:
13
Ex. 1012, Fig. 2 (annotated).
[1.3] wherein the array “[T]he data coding method uses a wavelet codec, with a
produces a minimum minimum 10-bits per pixel precision input.” Ex. 1012, p.7.
of 10-bits per pixel of
color data,
[1.4] and a frame The ’339 application teaches a frame grabber:

grabber capturing raw The pixel data is readout of the sensor at
image data output variable clock speeds or resolutions and is
from the imager on a captured thru a frame grabber. The images
selective continuous or output from the sensor may be captured by
intermittent basis and the frame grabber either continuously or
outputting a serial data intermittent basis.
rate of at least 48
megabytes per second Ex. 1012, p.3.
of non-interpolated the sensor and frame grabber can transmit
color filtered pixel non-interpolated and uncompressed data.
data; and
Ex. 1012, p.7.
the plurality of interfaces, between sensors
and one or more frame grabbers and between
14
the frame grabbers and processors, has a

bandwidth of at least 48 Megabytes per
second, between each sensor and frame
grabber.
Ex. 1012, p.9.
[1.5] a modular “The frame grabber may have on board memory to capture
processing sub-system full frame images or buffer the image data for transfer to
receiving output from the processing subsystem with its associated memory.”
the frame grabber, Ex. 1012, p.3.
The modular processing sub-system is also shown in
Figure 3 of the ’339 application as annotated below:
Ex. 1012, Fig. 3 (annotated).
[1.6] wherein the The ’339 application teaches that the modular processor
modular processing sub-system provides image processing and
sub-system further communication of the output from the frame grabber:
provides image The processor executes reprogrammable
processing and software to perform image processing for
communication of the visualization, analysis, or storage. The
output from the frame processor may be either dedicated hardware
grabber, and executes or general purpose CPU, GPU or DSP or
reprogrammable combination thereof.
software to perform an
image processing Ex. 1012, p.4. The ’339 application also teaches that the
function for modular processing sub-system executes programmable
visualization, analysis, hardware to perform image processing:
or storage; The image processing functions may include
image correction, interpolation, white
balance, color correction, color
15
transformation including the use of three

dimensional look-up tables, motion
detection, object detection and classification,
tracking, triangulation, calibration, color
keying, image mixing, stereographic
processing, anaglyph generation, indicator
overlay, focus detection, exposure metering,
zooming and scaling, flipping, data packing,
pattern matching and recognition, face
recognition, data rate analysis, enhancement,
stabilization and compression.
Ex. 1012, p.7.
[1.7] wherein light “The camera system uses optics to gather light from a
gathered by the optical desired scene to a pixilated sensor. The sensor captures
assembly is received high definition raw images at film or video rates. The
by the imager for sensor may be based on CMOS, CCD or other pixilated
generating and detection devices with color filters used to capture a
outputting raw image representation of the full color images. The pixel data is
data at film or video readout of the sensor at variable clock speeds or
rates. resolutions and is captured thru a frame grabber. The
images output from the sensor may be captured by the
frame grabber either continuously or intermittent basis.”
Ex. 1012, p.3.
Thus, Presler is properly supported and thus entitled to the filing date of
Provisional Application No. 60/923,339 (“the ’339 Application”) filed on April 13,
2007.
2. Molgaard
Molgaard teaches “lossless, near-lossless, and lossy compression and
decompression of digital image data.” Ex. 1006, Abstract. Molgaard’s processing
method “is optimized for raw image data from a sensor with a Bayer filter pattern.”
Id., Abstract.
16
3. Reasons to Combine
Further explanation of the reasons a POSITA would have combined Presler
and Molgaard to achieve the claimed limitations is found below in the element-by-
element analysis.
1. Claim 1
[1.0] A video camera comprising:
Presler discloses this limitation because it teaches “a digital camera system
that captures scalable resolution, bit-depth and frame rate raw or color processed
images … at precise film or video rates.” Ex. 1005, 3:51-55. A POSITA would
have recognized a digital camera system that captures images at “video rates” is a
“video camera.” Ex. 1003, p.34. A representation of Presler’s video camera is
reproduced below:
17
Ex. 1005, Fig. 8. Thus, Presler’s digital camera system satisfies the claimed “video
camera.” limitation. Ex. 1003, p.34.
[1.1] a portable housing having an opening through which light emanating from
outside the portable housing enters the portable housing;
Presler discloses this limitation because it teaches that its video camera can
be a “a portable digital camera and recording system.” Ex. 1005, 4:35-36. One
such example is shown in Fig. 8 below:
18
Opening where light enters Portable Housing
Ex. 1003, p.35; Ex. 1005, Fig. 8 (annotated). Based on this diagram, a POSITA
would have recognized that Presler’s video camera includes a “portable housing”
because the camera is specifically identified as a “mobile docking camera” and the
housing includes a handle. Ex. 1003, p.35. Thus, Presler’s video camera comprises
a portable housing.
Presler also teaches that its video camera includes an opening through which
light enters the portable housing. Specifically, Presler’s video camera “includes an
optical assembly 22 to gather light from a desired scene.” Ex. 1005, 6:13-16. As
19
shown in Fig. 8, optical assembly 22 is fitted on the portable housing and is thus an
opening that gathers light from outside the portable housing into the portable
housing.
Thus, Presler’s video camera with a portable housing and an optical
assembly that gathers light meets the claimed limitation “a portable housing having
an opening through which light emanating from outside the portable housing enters
the portable housing.”
[1.2] a memory device supported by the portable housing;
Presler discloses this limitation because it teaches storage device 44 included
within the housing of the portable video camera, as annotated in Fig. 8 below:
20
Memory
Ex. 1003, p.37; Ex. 1005, Fig. 8 (annotated).
In Presler, “storage device 44 can be either internal or external and either
fixed or removable.” Ex. 1005, 12:13-15. Examples of storage device 44 include
“non-volatile memory, flash memory, a magnetic hard drive, an optical disk and
tape.” Id., 12:15-18. Presler’s storage device 44 is thus “a memory device
supported by the portable housing” as claimed. Ex. 1003, p.37.
[1.3.0] an image sensor comprising first, second, and third pluralities of light
sensitive devices arranged with respect to one another in a plane defined by the
image sensor
21
The combination of Presler and Molgaard renders this limitation obvious.
First, Presler’s video camera includes an image sensor, as shown in Figure 8
below.
Image sensor
Ex. 1003, p.38; Ex. 1005, Fig. 8 (annotated). Presler’s image sensor can be “[a]
single image sensor” that “may include color filters that are used to capture a
representation of the full color images.” Ex. 1005, 6:32-34. One example color
filter disclosed by Presler is a Bayer filter. See Ex. 1005, 14:37-39.
22
Second, Molgaard similarly describes using an image sensor with a Bayer
filter (i.e., a three-color filter array) for capturing Bayer image data. See Ex. 1006,
8:30-33 (“Image sensor 14 can have any configuration of color filter pattern, e.g. a
Bayer pattern. Some image sensors generate red, green, and blue color components
straight into the image sensor array without the need for interpolation.”). A
POSITA would have recognized that Bayer filters, as taught by both Presler and
Molgaard, include a specific arrangement of light sensitive devices (i.e., color
filters). See Ex. 1003, p.39; Ex. 1007, p.1 (“Most digital cameras use image
sensors that sample only one of the three primary colors at each pixel position.
Specifically, each pixel is covered with a filter and records just one of the three
primary colors: red, green or blue.”); Ex. 1003, p.39.
Molgaard enhances Presler’s teachings by further disclosing an example
Bayer filter in Figure 9, reproduced below.
23
Ex. 1006, Fig. 9. As shown in Fig. 9, the filter consists of “first, second, and third
pluralities of light sensitive devices (i.e., red, green, and blue areas) arranged with
respect to one another in a plane defined by the image sensors” (i.e., in a 2D array).
A POSITA would have recognized that a Bayer filter would be arranged “in a
plane defined by the image sensor” because the purpose of the Bayer filter is to
cause the image sensor to capture one color value per pixel, which thus requires the
filter to be arranged on the plane of the image sensor where the image is focused.
Ex. 1003, p.40; Ex. 1016, Abstract.
A POSITA would have found it obvious to combine Molgaard’s teaching of
a Bayer filter (with three types of color filters arranged in a grid) with Presler’s
image sensor 30 because both systems describe using a single image sensor with a
Bayer filter to generate Bayer image data. See id., p.41; Ex. 1005, 14:37-39; Ex.
1006, 8:30-33; Ex. 1016, Abstract. Thus, Presler’s video camera combined with
Molgaard’s teaching of using an image sensor with a Bayer filter renders obvious
“an image sensor comprising first, second, and third pluralities of light sensitive
devices arranged with respect to one another in a plane defined by the image
sensor” as claimed.
[1.3.1] such that the first, second, and third pluralities of light sensitive devices
are intermingled, defining an intermingled pattern,
First, as discussed above in [1.3.0], Molgaard teaches using a Bayer filter array
24
with an image sensor. Ex. 1003, p.41; see also Ex. 1006, 8:30-35 (“Image sensor
14 can have any configuration of color filter pattern, e.g. a Bayer pattern. Some
image sensors generate red, green, and blue color components straight in the image
sensor array without the need for interpolation.”). As shown in Fig. 9, Molgaard’s
Bayer filter includes first, second and third pluralities of light sensitive devices
(i.e., red, green, and blue areas) arranged in an intermingled pattern:
Ex. 1006, Fig. 9. Based on these teachings, a POSITA would have recognized that
a Bayer filter includes a plurality of light sensitive devices defining an
intermingled pattern. Ex. 1003, p.42.
Thus, Presler’s video camera combined with Molgaard’s use of Bayer filter
renders obvious an image sensor comprising first, second, and third pluralities of
light sensitive devices arranged “such that the first, second, and third pluralities of
light sensitive devices are intermingled, defining an intermingled pattern” as
claimed.
25
[1.3.2] the first, second, and third pluralities of light sensitive devices being
configured to detect first, second, and third colors, respectively, the first, second,
and third colors being different from each other,
The combination of Presler and Molgaard renders this limitation obvious. As
discussed above in [1.3.0] and [1.3.1], Molgaard’s image sensor includes a Bayer
color filter array that captures Bayer pattern image data. Ex. 1003, p.43. As shown
in Molgaard’s Fig. 9, this pattern includes “first, second, and third pluralities of
light sensitive devices” (i.e., red, green, and blue areas):
Ex. 1006, Fig. 9. A POSITA would understand this to mean that each distinct pixel
is configured to detect one color, either red, green, or blue. Ex. 1003, p.43.
Thus, Presler’s video camera combined with Molgaard’s use of an image
sensor with a Bayer filter renders obvious the claimed “first, second, and third
pluralities of light sensitive devices being configured to detect first, second, and
third colors, respectively, the first, second, and third colors being different from
each other.”
26
[1.3.3] the image sensor being configured to convert light entering the portable
housing through the opening into raw mosaiced image data comprising one data
value for each of the light sensitive devices included in the first, second, and
third pluralities of light sensitive devices,
First, as discussed in [1.1] and [1.3.0], the combination of Presler and Molgaard
teaches claimed “image sensor being configured to convert light entering the
portable housing through the opening into raw mosaiced image data.” Ex. 1003,
p.43. Specifically, Presler teaches a video camera with an optical assembly and an
image sensor, as shown below:
27
Optical assembly for

Image sensor
passing light into housing
Id., p.44; Ex. 1005, Fig. 8 (annotated).
As discussed above in [1.1], the optical assembly “gather[s] light 24 from a
desired scene 26” so that the image sensor can “capture[] high definition raw
images at film or video rates.” Ex. 1005, 6:14-22. Presler’s image sensor is thus
configured to receive light entering the video camera and convert this light into
raw image video data. Ex. 1003, p.43.
As discussed in [1.3.0], Molgaard discloses using an image sensor, as in
Presler’s video camera, with a Bayer filter to produce “raw mosaiced image data.”
28
Id. A POSITA would have recognized this Bayer image data to be “raw mosaiced
image data” because Molgaard teaches that the Bayer image data is “raw image
data coming straight from the analog-digital converter 14 in a digital imaging
front-end.” See id., p.45; Ex. 1006, 8:27-29. A POSITA would have also
recognized that the Bayer image data generated by Molgaard’s sensor is
“mosaiced” because the data is formatted such that “primary color samples are
interleaved in a two-dimensional (2-D) grid, or color mosaic, resembling a three-
color checkerboard.” See Ex. 1003, p.45; Ex. 1007, p.1. Thus, the combination of
Presler and Molgaard renders obvious the claimed “image sensor being configured
to convert light entering the portable housing through the opening into raw
mosaiced image data.”
Second, as shown in Molgaard’s Fig. 9, the Bayer image data (i.e., the raw
mosaiced image data) “compris[es] one data value for each of the light sensitive
devices included in the first, second, and third pluralities of light sensitive
devices,” as claimed, because each value in the Bayer image data represents a
single color—red, green, or blue:
29
Ex. 1006, Figure 9.
Thus, Presler’s video camera combined with Molgaard’s teaching of
generating raw mosaiced image data at an image sensor renders obvious the
claimed image sensor “being configured to convert light entering the portable
housing through the opening into raw mosaiced image data comprising one data
value for each of the light sensitive devices included in the first, second, and third
pluralities of light sensitive devices.”
[1.3.4] the image sensor being configured to output the raw mosaiced image data
at a resolution of at least 2 k and at a frame rate of at least about 23 frames per
second; and
First, as discussed above in [1.3.3], the combination of Presler and Molgaard
disclose an image sensor that outputs “raw mosaiced image data.” See Ex. 1005,
16:13-26, 26:1-3; Ex. 1006, 8:27-29, Fig. 9; Ex. 1003, p.47. Second, Presler further
teaches that its video camera can capture image data, including data from a color
30
filtered sensor (e.g., a Bayer filter), at a resolution of 2k and at a rate of more than
23 frames per second. Ex. 1005, 10:18-21 (“A modular camera unit 28 that uses a
2K image sensor unit 30 can use [] at least one SMPTE 1.5 Gigabit/sec HD link to
transmit 2K raw image data at fifty (50) images per second with 10-bit per pixel
data.”). Molgaard similarly contemplates “at least 2 k” resolutions. Ex. 1006,
12:28 (“>4000 pixels in a line is common these days”). A POSITA would have
thus understood that Presler’s video camera configured using a Bayer filtered
image sensor would be configured to output raw mosaiced data at a resolution of at
least 2K and at least 23 frames per second (i.e., 50 images per second). Ex. 1003,
p.47.
Thus, the combination of Presler and Molgaard renders obvious the claimed
“image sensor being configured to output the raw mosaiced image data at a
resolution of at least 2 k and at a frame rate of at least about 23 frames per second.”
[1.4] electronics having an image processing module and a compression module

implemented therein,
Presler discloses this limitation because it teaches that its portable video
camera includes a modular processing, storage, and display system 134 (i.e.,
electronics) as shown below:
31
Electronics
Ex. 1003, p.48; Ex. 1005, Fig. 8 (annotated). The processing, storage and display
system 134 includes processor 36, which is “a computer based on an Intel Core 2
Duo T7600 2.33 GHz multi-core processor.” Ex. 1005, 21:39-45.
In Presler, the processor 36 execute several software modules including an
image processing module and a compression module. See Ex. 1005, 10:62-67
(“The processor 36 of the processing sub-system executes reprogrammable
software 38 that performs image processing for visualization, analysis, or
storage.”); Ex. 1005, 11:8-19 (“The reprogrammable software 38 can perform
various image processing functions including … compression.”). Based on
these teachings, a POSITA would understand that Presler’s processing unit 134
32
consists of electronics that implement both image processing and compression
modules in software. Ex. 1003, p.49. Thus, Presler’s video camera includes the
claimed “electronics having an image processing module and a compression
module implemented therein.”
[1.5.0] the image processing module connected between the image sensor and the
memory device,
teaches the claimed image sensor. Ex. 1003, p.49. Second, as discussed in [1.2],
Presler’s removable digital storage teaches the claimed memory device. Id., pp.49-
50. Third, as discussed in [1.4], Presler’s processing system 134 includes an image
processing module in software that executes on a processor 36 that is part of
processing system 134. Id., p.50.
Fourth, as shown in Presler’s Fig. 8, the processing system 134 is
“connected between” the image sensor and the removable digital storage. See Ex.
1005, 9:45-52. For example, Presler further teaches that its image processing
module is “connected between” the image sensor and the removable memory
because “the data link or data channel between the frame grabber 32 and the
processor 36 can transfer the raw . . . image data at variable speeds, which may
be below, at or above the readout rate of the image sensor unit 30.” Ex. 1005, 9:45-
52. The processor 36 then “executes software 38 that performs image processing
33
for visualization, analysis, or storage.” Ex. 1005, 10:62-64. The image data
processed by the image processing software can then be output by the processor to
a storage device. Ex. 1005, 11:55-57 (“The processor 36 can output raw image
data, image processed data or metadata in any combination for storage,
transmission or display.”). One available device for storing the image data is the
storage device 44 (i.e., a memory device) that “can be either internal or external
and either fixed or removable.” Ex. 1005, 12:13-15.
Based on these teachings, a POSITA would have recognized that the image
processing module in Presler is “connected between” the image sensor and the
removable memory because Presler teaches processing image data captured by the
sensor, processing that image data in a variety of possible ways, and then storing
the image data. A POSITA would also recognize that Presler’s memory device 44
would be one possible option for storing the image data. Ex. 1003, p.50.
Thus, Presler’s video camera with image processing software that processes
image data from an image sensor then stores the image data discloses the claimed
“image processing module connected between the image sensor and the memory
device.”
[1.5.1] the image processing module configured to process the raw mosaiced
image data from the image sensor and output processed image data based on the
raw mosaiced image data from the image sensor,
34
First, as discussed in [1.4] and [1.5.0], Presler’s processing system includes an
image processing module implemented in software that processes raw mosaiced
image data (i.e., Bayer image data) from the image sensor. Ex. 1003, p.51; see also
Ex. 1005, 12:42-52. For example, Presler states that “[t]he software 38 running on
the processor 36 can perform image and stereo processing functions in any
combination of general purpose processor or dedicated hardware, RISC arrays or
DSPs.” Ex. 1005, 13:30-34. A POSITA would have understood that processing
data from the image sensor (i.e., Bayer image data) would be processing raw
mosaiced image data. See Ex. 1003, p.51; Ex. 1005, 14:37-39. Presler also teaches
that its “processor 36 can output raw image data, image processed data or metadata
in any combination for storage, transmission or display.” Ex. 1005, 11:55-57.
Second, to the extent that Presler does not explicitly disclose processing raw
mosaiced image data and outputting processed data based on the raw mosaiced
image data, Molgaard teaches it. Specifically, Molgaard teaches a processing
method that “is optimized for raw image data from a sensor with a Bayer filter
pattern ….” Ex. 1006, Abstract. A POSITA would have recognized that raw image
data from a Bayer-filtered image sensor is raw mosaiced image data. Ex. 1003,
p.52.
35
In Molgaard, one available processing method includes “black calibration”
where:
[R]aw image data can be black calibrated to remove the fixed pattern
noise which is generated as a function of temperature as well as
integration time in the image sensor array. This process is called black
calibration as the fixed pattern which is subtracted is obtained while the
image sensor is not illuminated.
Ex. 1006, 9:15-20. A POSITA would understand this “black calibration” to process
raw mosaiced image data by subtracting a fixed pattern from the image data. Ex.
1003, p.52. A POSITA would also understand that this “subtraction” would result
in “processed image data based on the raw mosaiced image data” as claimed. Id.,
p.52.
processing raw mosaiced image data and outputting processed image data renders
obvious the claimed image processing module “configured to process the raw
mosaiced image data from the image sensor and output processed image data based
on the raw mosaiced image data from the image sensor.”
[1.5.2] the processed image data including less than three data values for each of
the light sensitive devices included in the first, second, and third pluralities of
light sensitive devices, and
First, as discussed in [1.5.1], Molgaard teaches processing raw mosaiced image
36
data by, for example, performing “black calibration” that subtracts a fixed pattern
from the image data. See Ex. 1006, 9:15-20; Ex. 1003, p.53. Molgaard further
teaches that this raw mosaiced image data (i.e., Bayer filter image data) includes
one data value for each of the pixels in the plurality of red pixels, one data value
for each of the pixels in the plurality of green pixels, and one data value for each of
the pixels in the plurality of blue pixels. See Ex. 1006, 8:26-40 (“Image sensor 14
can have any configuration of color filter pattern, e.g. a Bayer pattern. Some image
sensors generate red, green, and blue color components straight in the image
sensor array without the need for interpolation.”).
This is further shown in Molgaard’s Figure 9 showing a pixel cluster for a
Bayer filter pattern sensor (Ex. 1006, 12:5-13) where each pixel value represents
one color—red, greed, or blue:
Ex. 1006, Fig. 9; see also Ex. 1003, p.55.
37
Second, a POSITA would have recognized that the “black calibration”
process discussed in [1.5.1], where a fixed pattern is subtracted from the image
data, would still result in a single color value at each pixel, albeit possibly a
different value within the color range. Ex. 1003, p.53. Thus, Presler’s video camera
combined with Molgaard’s teaching of processing raw mosaiced image data with a
single value per pixel renders obvious the claimed “processed image data including
less than three data values for each of the light sensitive devices included in the
first, second, and third pluralities of light sensitive devices.”
[1.6.0] the compression module connected between the image sensor and the
memory device,
teaches the claimed image sensor. Ex. 1003, p.55. Second, as discussed in [1.2],
Presler’s removable digital storage teaches the claimed memory device. Id., p.55.
Third, as discussed in [1.4], Presler’s processing system 134 includes a
compression module implemented in software that executes on a processor 36 that
is part of processing system 134. Id., p.56.
Presler further teaches that its compression module is “connected between”
the image sensor and the removable memory because “the data link or data channel
between the frame grabber 32 and the processor 36 can transfer the raw or
processed image data at variable speeds, which may be below, at or above the
38
readout rate of the image sensor unit 30.” Ex. 1005, 9:45-52. The processor 36 then
executes software 38 (i.e., the image processing mode) that “perform[s]
compression and can employ a full-frame temporal Wavelet transform codec to
eliminate ‘block artifacts’ that are often present when using DCT compression.”
Ex. 1005, 13:46-49. Thus, Presler teaches that image data is input into the
compression module from the image sensor unit 30. See Ex. 1003, p.56; Ex. 1005,
13:46-49. Furthermore, Presler teaches that the image data, including processed
image data, is stored in the storage device 44. See Ex. 1005, 22:4-9. Therefore, a
POSITA would have recognized that Presler’s software—that performs
compression—is a compression module “connected between” the image sensor and
the removable memory. Ex. 1003, p.56; Ex. 1005, 13:46-49, 22:4-9. Thus,
Presler’s video camera with software that performs compression on image data
discloses the claimed “compression module connected between the image sensor
and the memory device.”
[1.6.1] the compression module configured to compress the processed image data
with a mathematically lossy compression technique into compressed processed
image data
First, as discussed in [1.10] and [1.11], Molgaard teaches “processed image data”
in that “black calibration” is performed by subtracting a fixed pattern from the raw
mosaiced image data. Ex. 1003, p.57; see also Ex. 1006, 9:15-25.
39
Second, Molgaard teaches compressing this processed image data using a
lossy compression technique: Ex. 1006, 10:32-34 (“The next stage in the algorithm
is an optional lossy bit reduction stage used to adjust the compression ratio, the
stage is bypassed if lossless compression is desired.”). A POSITA would have
recognized that compressing the processed image data would produce compressed
processed image data. Ex. 1003, p.58.
A POSITA would have been motivated to use the lossy compression
schemes of Molgaard to compress the processed image data produced with the
Presler’s imaging software 38 (i.e., “compression module”) because Molgaard’s
gamma correction and bit-reduction techniques reduce the amount of data required
to represent the processed image data, thereby allowing the processed image data
to be compressed faster and/or with less expensive hardware than if Presler’s
compression was applied to the processed raw data itself. Ex. 1006, 1:44–46,
2:59–3:14, 15:12–24; Ex. 1003, p.59. Also, Molgaard acknowledges errors that
may occur in lossy compression schemes and describes specific techniques to
overcome these problems: “If no precompression gain were applied, the errors
introduced by the lossy part of the compression would be amplified in the resulting
processed image. Ex. 1006, 10:15-18. Additionally, Molgaard discusses techniques
such as noise suppression that may be used to “improve[] image compression
ratios without sacrificing image quality.” Ex. 1006, 11:67-12:3. Molgaard also
40
teaches that its technique results in “very stable compression ratios,” which
“enables design of a surrounding digital imaging system which does not need a lot
of overhead.” Id. at 15:12–18. Molgaard also teaches that the “image quality
achieved is superior to what can be achieved with a standard baseline JPEG set to
1/8th compression, as visual artifacts are totally absent no matter which image is
being compressed.” Id. at 15:21–24. Thus, a POSITA would have been motivated
to implement Molgaard’s efficient data compression techniques to achieve a
superior compression ratio and image quality over Presler’s compression alone.
Ex. 1003, p.59.
compressing processed image data using a lossy compression technique renders
obvious the claimed “compression module configured to compress the processed
image data with a mathematically lossy compression technique into compressed
processed image data.”
[1.6.2] such that the compressed processed image data can be decompressed and
demosaiced into a substantially visually lossless image of at least 2 k resolution,
The combination of Presler and Molgaard renders this limitation obvious. As
discussed in [1.6.1], the combination of Molgaard’s teachings of compressing
processed image data with a mathematically lossy compression technique with
Presler’s video camera renders obvious the claimed “compression module
41
configured to compress the processed image data with a mathematically lossy
compression technique into compressed processed image data.” Ex. 1003, p.59.
Presler further teaches that compressed data can be decompressed and
demosaiced into a substantially visually lossless image of at least 2k resolution. Id.,
p.59. Specifically, as discussed in Section VII, a POSITA would have understood
“demosaiced” image data to include full-color motion video data reconstructed
from mosaiced motion video data. Id., p.59. The compressed image data generated
by Presler’s video camera can be decompressed and demosaiced because Presler’s
camera system includes functionality to “deliver[] unique display modes 2D and
3D representation of the multiple streams during live, recording, playback or post
processing” and is “capable of HD, 2K and 4K stereo-3D or wide dynamic multi-
image acquisition.” Ex. 1005, 4:30-39. Furthermore, a POSITA would have
understood Presler’s camera system to be capable of producing processed image
data with at least 2k resolution. See Ex. 1003, p.62; Ex. 1005, 23:10-14.
Additionally, Presler specifically teaches demosaicing Bayer image data
(i.e., mosaiced image data). Ex. 1005, 14:37-38 (“For bayer image sources, the
software 38 can be used to select the demosaic method.”). Thus, a POSITA would
have understood that Presler’s video camera can compress processed image data
“such that the compressed processed image data can be decompressed and
demosaiced” into an “image of at least 2k resolution” as claimed. Ex. 1003, p.61.
42
A POSITA would have also understood that the image data produced by
Presler’s video camera system and processed and compressed using Molgaard’s
compression techniques to be “substantially visually lossless” because Molgaard
teaches that “near-lossless compression is implemented using a gamma function to
provide a compression that is visually lossless as it only affects image data in the
same manner as the later image postprocessing, e.g. in relation to presenting
recorded images on a monitor or a printout.” Ex. 1006, 7:1-3; Ex. 1003, p.61. A
POSITA would have thus recognized that Molgaard’s method of compressing
processed image data can be performed using a lossy compression method that
produces a visually lossless decompressed image. Ex. 1003, p.61. A POSITA
would have further recognized that combining Molgaard’s image processing and
compression techniques into Presler’s video camera would be a simple inclusion of
software that operates according to Molgaard’s teachings. Id., p.61.
Thus, Presler’s video camera combined with Molgaard’s method of
compressing processed image data according to a lossy technique renders obvious
the claimed “compression module configured to compress the processed image
data ... such that the compressed processed image data can be decompressed and
demosaiced into a substantially visually lossless image of at least 2 k resolution.”
[1.7] wherein the memory device receives the compressed processed image data
at a rate of at least about 23 frames per second.
43
First, as discussed in [1.6.1], a POSITA would have understood that Presler’s
video camera combined with Molgaard’s compression techniques produces
compressed processed image data. Ex. 1003, p.63. In Presler, the compressed (i.e.,
coded) image data is output to a file that is “written to local or remote storage 432
on a project and auto file sequence naming basis.” Ex. 1005, 24:61-25:7. A
POSITA would have recognized that this coded image data includes compressed
processed image data. Ex. 1003, p.63. A POSITA would also have recognized that
storing the encoded image data to local or remote storage would include storing the
data on memory as shown in Fig. 8. Id., p.63. Similarly, Molgaard describes
techniques “whereby the image data can be compressed and decompressed on-the-
fly,” where “on-the-fly means that data is processed, here compressed or
decompressed, at the same rate as it is input to the relevant section.” Ex. 1006,
Abstract, 2:35–37.
Second, while Presler does not specifically provide a transfer rate for storing
compressed image data to memory, Presler provides a number of transmission
protocols that can be used for such purposes including the SATA protocol. See Ex.
1005, 12:13-23. Presler also teaches that its video camera is capable of capturing
2k and 4k images at more than 23 frames per second:
44
A modular camera unit 28 that uses a 2K image sensor unit 30 can use
at least one SMPTE 1.5 Gigabit/sec HD link to transmit 2K raw image
data at fifty (50) images per second with 10-bit per pixel data. A
modular camera unit 28 that uses a 4K image sensor unit 30 can use
two or more 3-Gigabit per second links to transmit 4K raw images at
minimum of 23.97 images per second with at least 10-bit precision.
Id., 10:18-28.
A POSITA would have understood that several of Presler’s transmission
methods are capable of transmitting and receiving image data at a rate sufficient to
store uncompressed 4k images at more than 23 frames per second. Ex. 1003, p.64.
For example, the SATA 2.6 specification (Ex. 1009) teaches that “Serial ATA
cables function at both 1.5 Gbps and 3.0 Gbps.” Ex. 1009, p.50. A POSITA would
have therefore recognized that Presler’s memory using an SATA transmission link
would receive image data at up to 3.0 Gbps per link. Ex. 1003, p.65. Thus,
Presler’s memory using an SATA transmission link could store both 4k image data
and 2k image data at the rate output by the image sensor. Id., p.65.
A POSITA would have also recognized that since Presler teaches storing
compressed/encoded image data that the transmission speed required for storing
such data would be less than that required for uncompressed image data. Id., p.65.
A POSITA would have thus concluded that Presler’s memory is capable of
receiving 2k and 4k compressed processed image data at a rate of at least 23
45
frames per second given the transmission capacity of the SATA transmission
method. Id., p.65.
Thus, Presler’s video camera combined with Molgaard teaching of
processing and compressing image data renders obvious the claimed memory
device “receiv[ing] the compressed processed image data at a rate of at least about
23 frames per second.”
2. Claim 2
[2.0] A video camera according to claim 1 wherein the image sensor is

configured to output the raw mosaiced image data at a resolution of at least 2 k
and at a frame rate of at least 23 frames per second,
This limitation would have been obvious for the same reasons discussed in
[1.3.4].
[2.1] wherein the compressed processed image data can be decompressed and
demosaiced into a visually lossless image of at least 2 k resolution,
[1.6.2].
[2.2] and wherein the memory device receives the compressed processed image
data at a rate of at least 23 frames per second.
[1.7].
46
3. Claim 3

configured to output the raw mosaiced image data at a resolution of at least 4 k,
As discussed above in [1.3.4], the combination of Presler and Molgaard
renders obvious an image sensor that outputs raw mosaiced image data at a
resolution of at least 2k. Ex. 1003, p.66. Presler also teaches that its video camera
can also utilize a 4k image sensor, thus outputting 4k raw mosaiced image data.
Ex. 1005, 10:18-28 (“A modular camera unit 28 that uses a 4K image sensor unit
30 can use two or more 3-Gigabit per second links to transmit 4K raw images at
minimum of 23.97 images per second with at least 10-bit precision.”). Thus, the
combination of Presler and Molgaard render this limitation obvious.
[3.1] and the compressed processed image data can be decompressed and
demosaiced into a substantially visually lossless image of at least 4 k resolution.
renders obvious decompressing and demosaicing processed image data into a
substantially visually lossless image of at least 2k resolution. Ex. 1003, p.67. As
also discussed in that same section, Presler teaches that its software 38, that
performs decompression and demosaicing operations, is capable of processing 4k
resolution image data. Ex. 1005, 13:49-53 (“The software 38 may have scalable
precision to operate on data from 10-bit and higher, with optimized arithmetic
precision based on source resolution, and scalable resolution to support a variety
47
of formats including HD, 2K and 4K.”). Thus, the combination of Presler and
Molgaard renders this limitation obvious.
4. Claim 4

configured to output the raw mosaiced image data at a resolution of at least 4 k
and at a frame rate of at least 23 frames per second,
As discussed above in [3.0], Presler teaches that its image sensor is capable
of outputting raw mosaiced image data at a resolution of at least 4k. Ex. 1003,
p.67. Presler also teaches that its image sensor is capable of outputting the raw
mosaiced image data at a frame rate of at least 23 frames per second (fps). Ex.
1005, 10:21-25 (“A modular camera unit 28 that uses a 4K image sensor unit 30
can use two or more 3-Gigabit per second links to transmit 4K raw images at
minimum of 23.97 images per second with at least 10-bit precision.”). Thus, the
combination of Presler and Molgaard renders this limitation obvious.
demosaiced into a visually lossless image of at least 4 k resolution,
[3.1].
data at a rate of at least 23 frames per second.
[1.7].
48
5. Claim 5
[5.0] A video camera according to claim 1 wherein the one data value for each of
the first plurality of light sensitive devices is representative of light of only the
first color, the one data value for each of the second plurality of light sensitive
devices is representative of light of only the second color, and the one data value
for each of the third plurality of light sensitive devices is representative of only
the third color,
As discussed above in [1.3.2], Molgaard’s Fig. 9 shows an example of
Bayer-filtered image data (i.e., data generated by a plurality of first, second, and
third light sensitive devices):
Ex. 1006, Fig. 9. As seen above, the image data generated for each pixel represents
a single color value—red, green, or blue. Accordingly, Molgaard’s use of a Bayer
filter teaches one data value being derived from each of the first, second, and third
light sensitive devices that each respectively represent only a first, second, or third
color. Ex. 1003, p.68. Thus, the combination of Presler and Molgaard renders this
limitation obvious.
49
[5.1] and wherein the processed image data does not include separate data values
for the first, second, and third colors for each of the light sensitive devices.
As discussed above in [1.5.2], Molgaard teaches generating processed image
data that has a single color value for each of the light sensitive elements of a Bayer
pattern filter. Ex. 1003, p.69. Specifically, Molgaard teaches that “[i]mage sensor
14 can have any configuration of color filter pattern, e.g. a Bayer pattern. Some
image sensors generate red, green, and blue color components straight in the image
sensor array without the need for interpolation.” Ex. 1006, 8:30-33.
As also discussed above in [1.5.1-1.5.2], Molgaard teaches outputting
processed image data by applying a “black calibration” process that subtracts a
fixed pattern from the mosaiced image data. See Id., 9:15-20. A POSITA would
have recognized that this “black calibrated” (i.e., processed) image data maintains
a single color value per pixel and would “not include separate data values for the
first, second, and third colors” for each pixel in the Bayer pattern. Ex. 1003, pp.69-
70. Thus, the combination of Presler and Molgaard renders this limitation obvious.
6. Claim 6
[6.0] A video camera according to claim 1 wherein the memory device is disposed
within the portable housing.
Presler disclosed this limitation because it teaches that its memory unit “can
be either internal or external and either fixed or removable.” Ex. 1005, 12:13-18.
50
Thus, Presler teaches a video camera with a memory device fixed within (i.e.,
internal to) the camera’s portable housing.
7. Claim 7
[7.0] A video camera according to claim 1 wherein the memory device is

supported on the outside of the portable housing.
Presler disclosed this limitation because it teaches that its memory unit “can
be either internal or external and either fixed or removable.” Ex. 1005, 12:13-18.
Thus, Presler teaches a video camera with a removable memory device supported
external (i.e., outside) to the camera’s portable housing.
8. Claim 8
[8.0] A video camera according to claim 1 additionally comprising a playback

module configured to receive the compressed processed image data from the
memory device,
Presler discloses this limitation because it teaches that its processor 36 can
execute a playback operation. Ex. 1005, 12:4-12. Specifically, Presler teaches that
“[t]he processor 36 can … perform specific tasks” including “start or stop
recording, initiate playback, … or select image processing or display modes.” Id.
Presler’s playback operation can be implemented in “software program 38 [that]
provides control of single and stereo image sources (i.e., imagery) with
synchronized image capture, frame grabbing, processing, metadata capture,
display, coding, recording and playback, using a single user interface.” Ex. 1005,
51
12:42-49. A POSITA would have recognized that software implementing a
playback operation is a playback module. Ex. 1003, p.72.
Presler also teaches that the playback operation retrieves image data from
the memory: “The software 38 running on the processor 36 records on a single
removable storage medium or to independent storage devices in a synchronized
fashion with common file naming conventions, to enable … playback.” Ex. 1005,
15:43-47. Further, as discussed above in [1.7], the combination of Presler and
Molgaard teaches storing compressed processed image data on a memory device.
Ex. 1003, p.73. Accordingly, a POSITA would have understood that Presler’s
playback module retrieves this compressed processed data for display. Id., p.73.
Thus, the combination of Presler and Molgaard renders this limitation obvious.
[8.1] and decompress and demosaic the compressed processed image data into
demosaiced image data that includes three data values for each of the light
sensitive devices included in the first, second, and third pluralities of light
sensitive devices.
teaches decompressing and demosaicing the compressed process image data. Ex.
1003, p.73. Presler further teaches using this same process for playback operations:
The capture or recorded image and data can be retrieved from storage
and placed back into the RAM buffer 414 for playback. The
playback engine can access the images and metadata from the ram
buffer 414 where it can be decoded 446 and unpacked and processed
52
thru the same processing, display visualization and image processing as

done during the live process, for display on one or more displays.
Ex. 1005, 25:10-24. A POSITA would have recognized that the demosaicing (i.e.,
interpolation) process would result in image data that includes three data values for
each pixel, as taught in Molgaard. Ex. 1003, p.74; see also Ex. 1006, 8:35-37.
9. Claim 9
[9.0] A video camera according to claim 1 wherein the compression module

comprises a compression chip.
First, Presler teaches compressing image data using, for example, “a
Wavelet Codec, such a Cineform or JPEG2000.” Ex. 1005, 22:61-66. Second,
Molgaard teaches implementing a compression algorithm in hardware, which
provides higher performance than software implementations: “The compression
section and the block can be implemented by hardware or software. The highest
performance can be achieved by implementing the algorithm hardware (e.g.
ASIC, FPGA) or software (using a processor Such as DSP Digital Signal
Processor)) which does not require external RAM capacity to be used.” Ex. 1006,
8:10-20.
A POSITA would find it obvious to modify Presler’s video camera to
implement its compression methods in hardware (e.g., in a chip) and would be
motivated to make such a combination since, as discussed in Molgaard,
53
implementing compression in hardware would achieve better performance that a
software implementation alone. Ex. 1003, pp.75-76. Thus, the combination of
Presler and Molgaard renders this limitation obvious.
10. Claim 10
[10.0] A video camera according to claim 1 wherein the compression technique

is a wavelet compression technique.
Presler discloses this limitation because it teaches “using a Wavelet Codec,
such a Cineform or JPEG2000.” Ex. 1005, 22:61-66. Thus, the combination of
Presler and Molgaard renders this limitation obvious.
11. Claim 12

configured to output the raw mosaiced image data at a resolution falling within a
range between and inclusive of 2 k and 4.5 k and at a frame rate falling within a
range between and inclusive of 23 and 120 frames per second,
resolution of at least 2k and a frame rate of at least 23 frames per second. Ex. 1003,
p.76. As also discussed above in [4.0], the combination of Presler and Molgaard
renders obvious outputting raw mosaiced image data at a resolution of at least 4k
and at a frame rate of at least 23 frames per second. Id., p.76. Thus, the
combination of Presler and Molgaard renders this limitation.
54
[12.1] wherein the compression module is configured to compress the processed

processed image data
[1.6.1].
[12.2] such that the compressed processed image data can be decompressed and
demosaiced into a substantially visually lossless image having a resolution
falling within a range between and inclusive of 2 k and 4.5 k resolution,
[1.6.2] for 2k resolution and [3.1] for 4k resolution.
data at a rate falling within a range between and inclusive of 23 frames per
second and 120 frames per second.
As discussed above in [1.7] and [4.2], the combination of Presler and
Molgaard renders obvious receiving compressed processed image data at a
memory device that is either 2k or 4k resolution and at a frame rate of at least 23
frames per second. Ex. 1003, p.77. Thus, the combination of Presler and Molgaard
renders this limitation obvious as discussed above.
12. Claim 13

configured to output the raw mosaiced image data at a resolution that is one of
2k, 4k, and 4.5 k and at a frame rate falling within a range between and
inclusive of 23 and 120 frames per second,
55
resolution of at least 2k and a frame rate of at least 23 frames per second. Ex. 1003,
p.78. As also discussed above in [4.0], the combination of Presler and Molgaard
renders obvious outputting raw mosaiced image data at a resolution of at least 4k
and at a frame rate of at least 23 frames per second. Id. Thus, the combination of
Presler and Molgaard renders this limitation obvious as discussed above.
[13.1] wherein the compression module is configured to compress the processed

[1.6.1].
demosaiced into a substantially visually lossless image having a resolution that is
one of 2 k, 4 k, and 4.5 k,
[1.6.2] for 2k resolution and [3.1] for 4k resolution.
As discussed above in [1.7] and [4.2], the combination of Presler and
Molgaard renders obvious receiving compressed processed image data at a
memory device that is either 2k or 4k resolution and at a frame rate of at least 23
56
frames per second. Ex. 1003, p.79. Thus, the combination of Presler and Molgaard
renders this limitation obvious as discussed above.
13. Claim 15
[15.0] A video camera according to claim 1 wherein the image sensor is a CMOS
sensor.
Presler discloses this limitation because it teaches that its “image sensor unit
can come in various forms including, without limitation, a complimentary metal-
oxide semiconductor (CMOS) active pixel image sensor ….” Ex. 1005, 6:26-34.
14. Claim 16
[16.0] A method of recording motion video with a camera, the method

comprising:
As discussed above in [1.0], Presler teaches a video camera for capturing
motion video data. Ex. 1003, pp.79-80. As discussed above in [1.2] and [1.7], the
combination of Presler and Molgaard teaches storing (i.e., “recording”) the motion
video data on a memory device. Id., pp.79-80. Thus, the combination of Presler
and Molgaard renders this limitation obvious.
[16.1.0] receiving light with an image sensor of a camera,
As discussed above in [1.1], Presler teaches a video camera with an opening
for light to pass through the system. Ex. 1003, p.80. As discussed in [1.3.0], the
combination of Presler and Molgaard teaches capturing the light at an image
57
sensor. Id., p.80. Thus, the combination of Presler and Molgaard renders this
limitation obvious as discussed above.
[16.1.1] the image sensor comprising first, second, and third pluralities of light
sensitive devices arranged with respect to one another in a plane defined by the
image sensor
[1.3.0].
[16.1.2] such that the first, second, and third pluralities of light sensitive devices
are intermingled, defining an intermingled pattern,
[1.3.1].
[16.1.3] the first, second, and third pluralities of light sensitive devices being
configured to detect first, second, and third colors, respectively, the first, second,
and third colors being different from each other;
[1.3.2].
[16.2] converting the light received by the image sensor into mosaiced image
data at a resolution of at least 2 k and at a frame rate of at least about 23 frames
per second, the mosaiced image data comprising one data value for each of the
light sensitive devices included in the first, second, and third pluralities of light
sensitive devices;
As discussed above in [1.3.3] the combination of Presler and Molgaard
renders obvious “converting the light received by the image sensor into mosaiced
image data …, the mosaiced image data comprising one data value for each of the
58
light sensitive devices included in the first, second, and third pluralities of light
sensitive devices.” Ex. 1003, p.81. As discussed above in [1.3.4], the combination
of Presler and Molgaard also renders obvious outputting the “mosaiced image data
at a resolution of at least 2k and at a frame rate of at least about 23 frames per
second ….” Id., p.81. A POSITA would have recognized that outputting image
data to a particular format (e.g., 2k at 23fps) would include converting the image
data to that format. Id., p.81. Thus, the combination of Presler and Molgaard
renders this limitation obvious as discussed above in [1.3.3] and [1.3.4].
[16.3.0] with electronics of the camera, processing the mosaiced image data from
the image sensor and outputting processed image data based on the mosaiced
image data from the image sensor,
As discussed in [1.4], Presler teaches electronics within a camera that
include an image processing module and a compression module. Ex. 1003, p.81.
As discussed in [1.5.1], the combination of Presler and Molgaard renders obvious
“processing the mosaiced image data from the image sensor and outputting
processed image data based on the mosaiced image data from the image sensor.”
Id., p.81. Thus, the combination of Presler and Molgaard renders this limitation
obvious as discussed above.
[16.3.1] the processed image data including less than three data values for each
of the light sensitive devices included in the first, second, and third pluralities of
light sensitive devices;
59
[1.5.2].
[16.4.0] with electronics of the camera, compressing the processed image data
with a mathematically lossy compression technique into compressed processed
image data
As discussed in [1.4], Presler teaches electronics within a camera that
include an image processing module and a compression module. Ex. 1003, p.82.
As discussed in [1.5.1], the combination of Presler and Molgaard renders obvious
“compressing the processed image data with a mathematically lossy compression
technique into compressed processed image data.” Id., p.82. Thus, the combination
of Presler and Molgaard renders this limitation obvious as discussed above.
[16.4.1] such that the compressed processed image data can be decompressed
and demosaiced into a substantially visually lossless image of at least 2 k
resolution; and
[1.6.2].
[16.5] recording the compressed processed image data onto a memory device of
the camera at a rate of at least about 23 frames per second.
As discussed in [1.7], the combination of Presler and Molgaard renders
obvious receiving “compressed processed image data at a rate of at least about 23
frames per second” at a memory device. Ex. 1003, p.82. A POSITA would find it
obvious that receiving this data at a memory device would be “recording” the data.
60
Id., pp.82-83. Thus, the combination of Presler and Molgaard renders this
limitation obvious as discussed above.
15. Claim 17
[17.0] A method according to claim 16 wherein said converting comprises

converting the light received by the image sensor into mosaiced image data at a
resolution of at least 2k and at a frame rate of at least 23 frames per second,
[16.2].
demosaiced into a visually lossless image of at least 2k resolution,
[2.1].
[17.2] and wherein said recording comprises recording the compressed processed
image data onto a memory device of the camera at a rate of at least 23 frames
per second.
[16.4].
16. Claim 18

resolution of at least 4k,
This limitation is substantially similar to the limitation discussed in [3.0] and
[16.2] and is rendered obvious as discussed above.
61
[18.1] and the compressed processed image data can be decompressed and
demosaiced into a substantially visually lossless image of at least 4 k resolution.
[3.1].
17. Claim 19

resolution of at least 4k and at a frame rate of at least 23 frames per second,
[4.0] and [16.2], and is rendered obvious by the prior art as discussed above.
demosaiced into a visually lossless image of at least 4k resolution,
[4.1].
[19.2] and wherein said recording comprises recording the compressed processed
image data onto a memory device of the camera at a rate of at least 23 frames
per second.
[4.2].
18. Claim 20
[20.0] A method according to claim 16 wherein the one data value for each of
the first plurality of light sensitive devices is representative of light of only the
first color,
62
[5.0].
[20.1] the one data value for each of the second plurality of light sensitive
devices is representative of light of only the second color,
[5.1].
[20.2] and the one data value for each of the third plurality of light sensitive
devices is representative of only the third color,
[5.2].
[20.3] and wherein the processed image data does not include separate data
values for the first, second, and third colors for each of the light sensitive
devices.
[5.3].
19. Claim 21
[21.0] A method according to claim 16 wherein said recording comprises

recording the compressed processed image data onto a memory device disposed
within a portable housing of the camera.
[6.0].
63
20. Claim 22
[22.0] A method according to claim 16 wherein said recording comprises

recording the compressed processed image data onto a memory device supported
on the outside of a portable housing of the camera.
[7.0].
21. Claim 23
[23.0] A method according to claim 16 additionally comprising: receiving the

compressed processed image data from the memory device with a playback
module implemented in the electronics of the camera;
[8.0].
[23.1] and decompressing and demosaicing the compressed processed image data
into demosaiced image data that includes three data values for each of the light
sensitive devices included in the first, second, and third pluralities of light
sensitive devices.
[8.1].
22. Claim 24
[24.0] A method according to claim 16 wherein the electronics comprise a

compression chip and said compressing is done using the compression chip.
[9.0].
64
23. Claim 25
[25.0] A method according to claim 16 wherein the mosaiced image data is raw
mosaiced image data.
As discussed above in [1.3.4], the prior art renders obvious the mosaiced
image data being raw mosaiced image data. Ex.1003, p.88.
24. Claim 26
[26.0] A method according to claim 16 wherein the compression technique is a

wavelet compression technique.
[10.0].
25. Claim 28

resolution falling within a range between and inclusive of 2 k and 4.5 k and at a
frame rate falling within a range between and inclusive of 23 and 120 frames per
second,
[12.0].
[28.1] wherein said compressing comprises compressing the processed image

data with a mathematically lossy compression technique into compressed
[12.1].
65
demosaiced into a substantially visually lossless image having a resolution
falling within a range between and inclusive of 2 k and 4.5 k resolution,
[12.2].
[28.3] and said recording comprises recording the compressed processed image
[12.3].
26. Claim 29

resolution that is one of 2k, 4 k, and 4.5 k and at a frame rate falling within a
range between and inclusive of 23 and 120 frames per second,
[13.0].
[29.1] wherein said compressing comprises compressing the processed image

data with a mathematically lossy compression technique into compressed
[13.1].
demosaiced into a substantially visually lossless image having a resolution that is
one of 2 k, 4 k, and 4.5 k,
66
[13.2].
[29.3] and said recording comprises recording the compressed processed image
[13.3].
D. Claims 11 and 27 are obvious over Presler in view of Molgaard,

further in view of Sodini.
1. Sodini
Sodini teaches a method to “process non-linear image data, still or video,
from a digital imager.” Ex. 1013, Abstract. Sodini teaches techniques for making
improvements to the light and dark balance of image data. See Ex. 1013, 8:24-28,
10:51-11:6. One process taught by Sodini is a “smoothing filter” that eliminates
single pixel defects caused in an image sensor “by clamping a predetermined pixel
of image data within the window when the value of the predetermined pixel is
greater than a maximum value of the image data of neighboring pixels or less than
a minimum value of the image data of neighboring pixels.” Id.
A POSITA would have found it obvious to combine Sodini’s smoothing
filter with the teaching of Presler and Molgaard since Molgaard’s image processing
method seeks to remove “fixed pattern noise” and “other blemishes like dead
67
columns, cluster defects, etc.” from Bayer image data. See Ex. 1006, 9:36-39. A
POSITA would have understood that Sodini’s smoothing filter applied to
Molgaard’s method would improve the method’s ability to remove blemishes and
defects caused by the image sensor by clamping pixel values that exceed
predetermined minimum or maximum values. Ex. 1003, p.93. A POSITA would
have also recognized that incorporating Sodini’s smoothing filter in Molgaard’s
method would substantially reduce ripples in the image caused by single pixel
defects. Ex. 1013, 9:11-13; Ex. 1003, p.93.
3. Claim 11
[11.0] A video camera according to claim 1 wherein the image processing

module is configured to process the raw mosaiced image data at least in part by
applying a pre-emphasis function to the raw mosaiced image data, wherein the
pre-emphasis function is configured to increase data values of the mosaiced
image data corresponding to relatively dark image regions and to decrease data
values of the mosaiced image data corresponding to relatively bright image
regions.
As discussed in [1.5.0] and [1.5.1], the combination of Presler and Molgaard
discloses an image processing module that processes raw mosaiced image data
from the image sensor. Ex. 1003, p.93. Sodini further enhances the image
processing capabilities of Presler and Molgaard by disclosing a “smoothing filter
on a color filter array” that eliminates manufacturing defects or pixel failure in an
image sensor. Ex. 1013, 8:12-21, Abstract. For example, Sodini applies a 3x5
smoothing filter to Bayer image data (i.e., raw mosaiced image data) that “clamps
68
pixels of image data which are greater than the maximum value of the image data
of neighboring pixels or less than the minimum value of the image data of
neighboring pixels.” Id., 8:24-28. Since pixel values represent illumination levels
(e.g., with “0 being no illumination and 255 being saturation” (id., 1:55-56)), a
POSITA would have recognized that “clamping” pixel values greater than a
maximum value would decrease relatively bright pixel values and “clamping”
pixel values less than a minimum value would increase relatively dark pixel values.
Ex. 1003, p.93.
Thus, the Sodini’s smoothing filter combined with the teaching of Presler
and Molgaard renders obvious the claimed “pre-emphasis function” that increases
data values of relatively dark image regions and decreases data values of relatively
bright image regions. Id., p.94.
4. Claim 27
[27.0] A method according to claim 16 wherein said processing the image data
comprises processing the mosaiced image data at least in part by applying a pre-
emphasis function to the mosaiced image data, wherein the application of the
pre-emphasis function increases data values of the mosaiced image data
corresponding to relatively dark image regions and decreases data values of the
mosaiced image data corresponding to relatively bright image regions.
[11.0].
69
E. Claims 14 and 30 are obvious over Presler in view of Molgaard,

further in view of Frost.
1. Frost
Frost teaches a portable storage device “compatible with both standard and
high definition digital video cameras.” Ex. 1014, Abstract. Frost’s device is
intended to meet a then existing need for a “digital media device that is compact
and light weight, thus allowing it to be easily transported and mounted directly to a
camera, as well as being robust, compatible with a variety of camera systems (e.g.,
high definition, standard definition, etc.), capable of interfacing with both cameras
and editing hardware, and user friendly.” Id., 1:48-54.
A POSITA would have found it obvious to combine the teachings of Frost
with Presler and Molgaard because Presler’s camera uses a storage device “either
internal or external and either fixed or removable,” (Ex. 1005, 12:14-15), and
Frost’s portable storage device is “compatible with both standard and high
definition digital video cameras.” Ex. 1014, 1:58-60. Further, Frost’s storage
device “is compact and light weight, thus allowing it to be easily transported and
mounted directly to a camera, as well as being robust, compatible with a variety of
camera systems (e.g., high definition, standard definition, etc.), capable of
interfacing with both cameras and editing hardware, and user friendly.” Id., 1:48-
53. Thus, a POSITA would have recognized that Frost’s storage device is the type
70
of storage device that could be included in Presler’s video camera to satisfy the
large storage requirements for high resolution video data. Ex. 1003, p.96. A
POSITA also would have recognized that Frost’s storage device is compatible with
Presler’s camera since both teach using high-speed data transmission such as
SATA and PCIe. See Ex. 1005, 12:13-23; Ex.1014, 1:64-2:5.
3. Claim 14
[14.0] A video camera according to claim 1 wherein the memory device is

sufficiently large to store image data from the compression module
corresponding to at least about 30 minutes of video at 12 mega pixel resolution,
12-bit color resolution, and at 60 frames per second.
First, as discussed above in section VII.D, this term requires a memory
device with a capacity of at least 324 gigabytes. Second, Frost discloses this
limitation because its portable storage device is “compatible with both standard
and high definition digital video cameras.” Ex. 1014, 1:59-60. Frost’s storage
device has a minimum capacity of 512 gigabytes since it preferably “includes two
memory boards, each of which includes sixteen memory modules divided into
four groups.” Id., 2:20-22. Each memory module is preferably “capable of storing
at least 16 gigabytes ….” Id., 2:13-14. Thus, Frost’s storage device added to
Presler’s video camera provides capacity sufficient to store 324 gigabytes of
compressed video data as required by this claim.
71
4. Claim 30
[30.0] A method according to claim 16 wherein the memory device is sufficiently

large to store image data from the compression module corresponding to at least
about 30 minutes of video at 12 megapixel resolution, 12-bit color resolution,
and at 60 frames per second.
[14.0].
X. CONCLUSION
For the reasons set forth above, Petitioner establishes a reasonable likelihood
that claims 1-30 are unpatentable. Petitioner requests institution of an inter partes
review and cancellation of challenged claims.
Respectfully submitted,
Dated: May 6, 2019 /Michael S. Parsons/

HAYNES AND BOONE, LLP Michael S. Parsons
2323 Victory Avenue, Suite 700 Lead Counsel for Petitioner
Dallas, Texas 75219 Registration No. 58,767
Customer No. 27683
Telephone: 972-739-8611
Facsimile: 214-200-0853
72
CERTIFICATE OF WORD COUNT
Pursuant to 37 C.F.R. § 42.24(d), Petitioner hereby certifies, in accordance
with and reliance on the word count provided by the word-processing system used
to prepare this petition, that the number of words in this paper is 13,904. Pursuant
to 37 C.F.R. § 42.24(d), this word count excludes the table of contents, table of
authorities, mandatory notices under § 42.8, certificate of service, certificate of
word count, appendix of exhibits, and any claim listing.
Dated: May 6, 2019 /Michael S. Parsons/

Michael S. Parsons
Lead Counsel for Petitioner
Registration No. 58,767
73
CERTIFICATE OF SERVICE
The undersigned certifies that, in accordance with 37 C.F.R. § 42.6(e) and
37 C.F.R. § 42.105, service was made on Patent Owner as detailed below.
Date of service May 6, 2019
Manner of service Federal Express

Documents served Petition for Inter Partes Review of U.S. Patent No.
9,245,314; Petitioner’s Exhibit List; Exhibits 1001–1014,
1016.
Persons served Knobbe Martens Olson & Bear LLP
2040 Main Street
Fourteenth Floor
Irvine, CA 92614
/Michael S. Parsons/
Michael S. Parsons
Lead Counsel for Petitioner
Registration No. 58,767
74

Apple Petition For Invalidation of Patent 9245314

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Apple Petition For Invalidation of Patent 9245314

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UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

PETITION FOR INTER PARTES REVIEW OF

U.S. PATENT NO. 9,245,314

II. MANDATORY NOTICES .............................................................................1

A. Real Party-in-Interest ........................................................................... 1

C. Lead and Back-up Counsel and Service Information .......................... 1

III. GROUNDS FOR STANDING ........................................................................2

IV. PAGE CITATIONS AND EMPHASIS ..........................................................2

V. THE ’314 PATENT .........................................................................................3

VI. LEVEL OF ORDINARY SKILL IN THE ART .............................................6

VII. CLAIM CONSTRUCTION ............................................................................6

A. “Raw Mosaiced Image Data” ............................................................... 7

B. “Demosaiced Motion Video Data” ...................................................... 8

C. “Substantially Visually Lossless” ........................................................ 9

D. “the memory device is sufficiently large to store image data from

VIII. RELIEF REQUESTED AND THE REASONS FOR THE

IX. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE ....10

A. Challenged Claims ............................................................................. 10

B. Statutory Grounds for Challenge........................................................ 10

3. Reasons to Combine ................................................................ 17

10. Claim 10 ................................................................................... 54

11. Claim 12 ................................................................................... 54

12. Claim 13 ................................................................................... 55

13. Claim 15 ................................................................................... 57

14. Claim 16 ................................................................................... 57

15. Claim 17 ................................................................................... 61

16. Claim 18 ................................................................................... 61

17. Claim 19 ................................................................................... 62

18. Claim 20 ................................................................................... 62

19. Claim 21 ................................................................................... 63

20. Claim 22 ................................................................................... 64

21. Claim 23 ................................................................................... 64

22. Claim 24 ................................................................................... 64

23. Claim 25 ................................................................................... 65

24. Claim 26 ................................................................................... 65

25. Claim 28 ................................................................................... 65

26. Claim 29 ................................................................................... 66

D. Claims 11 and 27 are obvious over Presler in view of Molgaard,

2. Reasons to Combine ................................................................ 67

E. Claims 14 and 30 are obvious over Presler in view of Molgaard,

2. Reasons to Combine ................................................................ 70

CERTIFICATE OF WORD COUNT ......................................................................73

CERTIFICATE OF SERVICE ................................................................................74

PETITIONER’S EXHIBIT LIST

Ex. 1001 U.S. Patent No. 9,245,314

Inc., respectfully requests that these claims be canceled.

II. MANDATORY NOTICES

The real party-in-interest is Apple Inc.

C. Lead and Back-up Counsel and Service Information

Andrew S. Ehmke Phone: (214) 651-5116

Jordan Maucotel Phone: (972) 739-8621

Please address all correspondence to lead and back-up counsel. Petitioner

consents to electronic service via email.

III. GROUNDS FOR STANDING

filed a civil action challenging the validity of any claim.

IV. PAGE CITATIONS AND EMPHASIS

added for compliance with 37 C.F.R. § 42.63(d)(2)(ii). Petitioner’s citations to the

underline emphasis in any quoted material has been added.

V. THE ’314 PATENT

The ’314 patent is directed to “a video camera” configured to “capture,

The ’612 application is a continuation of a string of applications that originate with

a continuation of U.S. Patent Application No. 12/101,882 (“the ’882 application”).