The Delhi High Court has directed for grant of a patent titled ‘Reversible 2-Dimensional Pre-/Post-Filtering for Lapped Biorthogonal Transform', which was related to a digital media (e.g., video and image) processor and the manner in which the processor is programmed for compression of two-dimensional digital media using lapped transforms.
The subject invention was noted as enhancing the functionality of the transform coding approach by detailing specific steps and methods that improve the efficiency and reversibility of the encoding and decoding processes, through a series of operations including reversible overlap operators and block transforms, which are crucial for reducing artifacts and improving the quality of compressed digital media. It was also observed that the claims articulated a specific approach to applying these techniques, thereby enhancing the traditional transform coding methods used in digital media compression.
Relying upon its recent decision in the case of Lava International Ltd. v. Telefonaktiebolaget LM Ericsson, the Court noted that in case of an invention involving computer programmes, to circumvent the limitations imposed by Section 3(k) of the Patents Act, 1970, the inventive contribution of a patent should also achieve an innovative technical advantage that is clearly defined and distinct from ordinary operations expected of such systems.
Allowing the appeal, the Court in Microsoft Technology Licensing, LLC. v. Assistant Controller of Patents and Designs noted that the subject patent application disclosed a method and system that not only provided a real-world application for complex mathematical transformations, including lapped transforms and reversible overlap operators, but also integrated these operations into a hardware setup that performs digital media data compression, thus enhancing the functionality of the general-purpose computers. It was of the view that the invention transforms the capabilities of general-purpose computing hardware into a specialised apparatus capable of efficient and effective data compression, which it otherwise was not expected to be capable of.
The High Court also held that the Controller erred in applying the novel hardware criteria by following Computer Related Invention Guidelines, 2016, which were already replaced by the Computer Related Guidelines, 2017, removing the requirement of a novel hardware.
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