Delhi High Court Upholds Refusal of NEC's Video Coding Patent Over Findings of Obviousness - 2026-03-28

Decoding the Ruling: Why the Delhi High Court Denied NEC's Patent Bid

In a significant decision for the telecommunications and video technology sector, the High Court of Delhi has upheld the refusal of NEC Corporation’s patent application titled “Video Coding Device, Video Decoding Device, Video Coding Method, Video Decoding Method and Program.” Presided over by Justice Tejas Karia, the court affirmed that the proposed invention lacked the necessary inventive step under Section 2(1)(ja) of the Patents Act, 1970.

Case Background

NEC Corporation had filed a patent application for advanced video coding technology—a system attempting to optimize compression efficiency through adaptive color transforms in the residual domain coupled with chroma quantization offsets. The Assistant Controller of Patents and Designs had previously rejected the application in June 2022, citing several prior arts (D1, D2, and D3) that allegedly rendered the invention obvious to a person skilled in the art (PSITA). NEC challenged this refusal in the Delhi High Court, arguing that their invention contained distinct technical features not present in existing literature.

Arguments from the Trenches

The Appellant (NEC) contended that the Controller failed to map the specific innovative features of their coding device against the existing prior art. NEC argued that earlier documents, such as the HEVC Screen Content Coding Draft Text (D1), did not conceptualize the derivation of adaptive chroma quantization offsets for a plurality of color spaces.

The Respondent, represented by the Assistant Controller, stood by the initial refusal. They argued that the technical differentiating features claimed by NEC were effectively disclosed in the cited prior art. Specifically, the Respondent highlighted that D1 and D2 discussed adjusting quantization parameters based on transform flags, making the Appellant's claimed adaptive mechanism an obvious progression for any expert in the field.

Legal Analysis: The Threshold of 'Obviousness'

The Court’s analysis centered on whether the jump between the prior art and the Appellant’s application was significant enough to merit patent protection. Referencing established principles, the Court noted that once a prime facie case of obviousness is established by the objector, the burden shifts to the inventor to prove why the invention is not merely an obvious iteration of established science.

Justice Karia found that the prior art clearly taught the derivation of adjustment factors for color components. The Court observed that because the prior art enabled switching between color spaces at the coding unit level, the Appellant’s claims regarding "deriving a chroma quantization offset for each of the plurality of color spaces" did not constitute a non-obvious breakthrough.

Key Observations

The judgment offers critical guidance on how patent claims are construed against prior art:

• On the nature of obviousness: “The obviousness is a question of law based on facts and the burden to prove is on the party which alleges however, after the party which alleges makes out a prima facie case of invalidity on the ground of obviousness, the burden shifts on the inventor to disapprove obviousness.”
• On prior art disclosures: “It would be obvious for a PSITA to derive that if the color space transform is not applied, the ‘normal’ QP should remain unmodified and therefore, implying a delta QP offset of 0.”
• On the rejection of the Appellant's narrow interpretation: “Therefore, the contentions advanced by the Appellant that D1 to D3 are confined merely to color space conversion... and do not disclose the concept of selecting a color space... is found to be untenable.”

The Final Verdict: Implications for Tech Patents

The High Court ultimately dismissed the appeal, holding that the subject matter of the invention was rendered obvious by the combination of documents D1, D2, and D3. For future applicants, this case serves as a clear warning: technical complexity alone is insufficient to secure a patent. An applicant must demonstrate that their methodology is not just "new," but that it overcomes technical barriers in a way that an expert—armed with existing industry literature—would not have inherently conceived.

This decision reinforces the high threshold required for "inventive step" claims in the rapidly evolving landscape of standardized video coding and compression technologies.