M & K Holdings, Inc. v. Samsung Electronics Co., Ltd., No. 20-1160 (Fed. Cir. 2021)
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The patent at issue is directed to an efficient method for compressing video files; its claims generally concern “a method of decoding a moving picture in inter prediction mode,” in which “one or more reference pictures are used to estimate motion of a current block” over the time of the video. In inter partes review, the Patent Trial and Appeal Board found all claims unpatentable.
The Federal Circuit affirmed in part and vacated with respect to claim 3. The court rejected an argument that the Board erred by relying on references that do not qualify as prior art printed publications under 35 U.S.C. 102. Substantial evidence supports the Board’s finding that persons of ordinary skill in video-coding technology could have accessed the references with reasonable diligence; those references constitute printed publications within the meaning of 35 U.S.C. 102. The Board erred by finding claim 3 anticipated when the petition for inter partes review asserted only obviousness as to that claim.
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