Prosecution Insights
Last updated: October 02, 2026
Application No. 18/946,632

METHOD AND APPARATUS FOR RECOGNITION OF A MOTION IN A VIDEO

Non-Final OA §101§102§103
Filed
Nov 13, 2024
Priority
May 13, 2022 — IN 202241027759 +1 more
Examiner
WASHINGTON, JAMARES
Art Unit
Tech Center
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
81%
Grant Probability
Favorable
1-2
OA Rounds
8m
Est. Remaining
93%
With Interview

Examiner Intelligence

Grants 81% — above average
81%
Career Allowance Rate
569 granted / 699 resolved
+21.4% vs TC avg
Moderate +11% lift
Without
With
+11.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
15 currently pending
Career history
712
Total Applications
across all art units

Statute-Specific Performance

§101
8.6%
-31.4% vs TC avg
§103
60.6%
+20.6% vs TC avg
§102
24.8%
-15.2% vs TC avg
§112
5.0%
-35.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 699 resolved cases

Office Action

§101 §102 §103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statements (IDS) submitted on 11/13/2024, 08/07/2025, 05/11/2026 and 08/26/2026 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statements are being considered by the examiner. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-15 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claims recite obtaining a plurality of image frames by capturing at least one object on a ground plane, detecting a motion of the at least one object and displacement/motion of the ground plane, estimating a path or trajectory of the plane, correcting the motion of the object in the image frames based on the trajectory of the plane and recognizing an action of the object. The abstract idea encompasses mental processes in which an individual visually acquires an object depicted in image frames, analyzes movement/motion of an object in the frames relative to the displacement of the ground, interpolates/estimates a displacement of the ground plane and correcting a location of the object in the frames as “motion” of the object with respect to the ground. This judicial exception is not integrated into a practical application because there is no meaningful limitations beyond generally linking the use of an abstract idea to a particular technical environment. Furthermore, the process or method steps performed are not enough to qualify as “significantly more” than the abstract idea itself as the steps may be performed in the human mind as a mental process in collecting images, analyzing an object in the images, and manipulating the object in the images to make a determination in regards to an action performed by the object in the image with respect to the ground plane of the frames. The claims further describe the identification of coordinates of the ground plane, obtaining a rotation value of the ground plane by using a rotation angle obtained in accordance with a trigonometrical function, obtaining a translation value of the ground plane and estimating the trajectory based on the rotation value and translation value. The method steps appear to be no more than manipulating data utilizing mathematical formulas or relationships to calculate relative trajectories. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more than the abstract idea. The claims recite an electronic apparatus comprising a memory and at least one processor. The aforementioned additional elements amount to merely using generic computer components to implement general processing and display of video images to a user while the user makes desired determinations. Generic computer components recited as performing generic functions that are well-understood, routine and conventional amount to no more than implementing the abstract idea with a computerized system. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified abstract idea. There is no indication that the elements improve the functioning of a computer or improves any other technology. Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1, 2, 7-10, 14 and 15 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Zhonghua Ma (US 20120327220 A1). Regarding claim 1, Ma discloses a method for recognizing an action of at least one object in a plurality of images (¶ [46]), the method comprising: obtaining a plurality of image frames by capturing at least one object on a ground plane (¶ [46]); detecting a motion of the at least one object (¶ [58]) and a motion of the ground plane in each of the plurality of image frames (¶ [85] and ¶ [97-100] wherein the differences in the ground plane with respect to the object and camera locations are detected); estimating a trajectory of the ground plane by tracking the motion of the ground plane (¶ [97] and ¶ [110] estimating horizon line with respect to ground plane as it corresponds to the location of the object in the images); correcting the motion of the at least one object in each of the plurality of image frames based on the trajectory of the ground plane (¶ [100-103] and ¶ [155] wherein the accuracy of an object’s motion with respect to its trajectory is confirmed); and recognizing the action of the at least one object based on the corrected motion of the at least one object (¶ [5] interpreting behaviors and events; and ¶ [59-60] detecting and tracking movement of an object utilizing 3D coordinate information correlates to “recognizing the action” of the object). Regarding claim 2, Ma discloses the method of claim 1 (see rejection of claim 1), wherein the detecting the motion of the at least one object comprises: obtaining a plurality of key points of the at least one object in the plurality of image frames (¶ [105-106]; Fig. 14A); and detecting the motion of the at least one object based on the plurality of key points (¶ [105]). Regarding claim 7, Ma discloses the method of claim 1 (see rejection of claim 1), wherein the correcting the motion of the at least one object comprises: estimating a trajectory of the at least one object based on the motion of the at least one object (¶ [152-153] track interpolation); obtaining a second correction value based on the trajectory of the object and the trajectory of the ground plane (¶ [156]); and correcting the motion of the at least one object based on the second correction value (¶ [156] track interpolation processing produces missing trajectory for completing the path of object motion). Regarding claim 8, Ma discloses an electronic apparatus for recognizing an action of at least one object in a plurality of image frames of a video (¶ [23]), the apparatus comprises: a memory (¶ [23]); at least one processor communicably coupled to the memory (¶ [23]), the at least one processor being configured to: obtain a plurality of image frames by capturing at least one object on a ground plane (see rejection of claim 1); detect a motion of the at least one object and a motion of the ground plane in each of the plurality of image frames; estimate a trajectory of the ground plane by tracking the motion of the ground plane (see rejection of claim 1); correct the motion of the at least one object in each of the plurality of image frames based on the trajectory of the ground plane (see rejection of claim 1); and recognize the action of the at least one object based on the corrected motion of the at least one object (see rejection of claim 1). Regarding claim 9, Ma discloses the apparatus of claim 8 (see rejection of claim 8), wherein the at least one processor is further configured, to detect the motion of the at least one object, to: obtain a plurality of key points of the at least one object in the plurality of image frames (see rejection of claim 2); and detect the motion of the at least one object based on the plurality of key points (see rejection of claim 2). Regarding claim 10, Ma discloses the apparatus of claim 8 (see rejection of claim 8), wherein the at least one processor is further configured, to estimate the trajectory of the ground plane, to: identify one or more coordinates of the ground plane of each of the plurality of image frames (see rejection of claim 3); obtain a rotation value of the ground plane along at least one axis by using a rotation angle obtained in accordance with a trigonometrical function (see rejection of claim 3); obtain a translation value of the ground plane based on the one or more coordinates of the ground plane (see rejection of claim 3); and estimate the trajectory of the ground plane based on the rotation value and translation value of the ground plane (see rejection of claim 3). Regarding claim 14, Ma discloses the apparatus of claim 8 (see rejection of claim 8), wherein the at least one processor is further configured, to correct the motion of the at least one object, to: estimate a trajectory of the at least one object based on the motion of the at least one object (see rejection of claim 7); obtain a second correction value based on the trajectory of the object and the trajectory of the ground plane (see rejection of claim 7); and correct the motion of the at least one object based on the second correction value (see rejection of claim 7). Regarding claim 15, Ma discloses a non-transitory computer readable medium having instructions stored therein, which when executed by a processor of a device cause the processor to execute a method (¶ [23]) comprising: obtaining a plurality of image frames by capturing at least one object on a ground plane (see rejection of claim 1); detecting a motion of the at least one object and a motion of the ground plane in each of the plurality of image frames (see rejection of claim 1); estimating a trajectory of the ground plane by tracking the motion of the ground plane (see rejection of claim 1); correcting the motion of the at least one object in each of the plurality of image frames based on the estimated trajectory of the ground plane (see rejection of claim 1); and recognizing an action of the at least one object based on the corrected motion of the at least one object (see rejection of claim 1). Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 3, 5 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Zhonghua Ma (US 20120327220 A1) in view of Adam Rowell et al (US 20190158813 A1). Regarding claim 3, Ma discloses the method of claim 1 (see rejection of claim 1), wherein the estimating the trajectory of the ground plane comprises: identifying one or more coordinates of the ground plane of each of the plurality of image frames (¶ [86]); obtaining a rotation value of the ground plane along at least one axis (¶ [137]); obtaining a translation value of the ground plane based on the one or more coordinates of the ground plane (¶ [103]); and estimating the trajectory of the ground plane based on the rotation value and translation value of the ground plane (¶ [157]). Ma fails to explicitly disclose obtaining a rotation value by using a rotation angle obtained in accordance with a trigonometrical function. Rowell, in the same field of endeavor of tracking objects using video sequenced image frames (¶ [45]), discloses obtaining a rotation value by using a rotation angle obtained in accordance with a trigonometrical function (¶ [84] and ¶ [113-114]). It would have been obvious to one of ordinary skill in the art before the invention was effectively filed for the method for recognizing an action of at least one object in a plurality of images as disclosed by Ma comprising obtaining a plurality of image frames and estimating a trajectory of a ground plane by tracking the motion of the ground plane to utilize the teachings of Rowell which teaches obtaining a rotation value by using a rotation angle obtained in accordance with a trigonometrical function to correct changes and distortions in imaging positions with respect to the baseline coordinates in the acquired images to provide accurate image rectification for moving objects. Regarding claim 5, Ma discloses the method of claim 1 (see rejection of claim 1). Ma fails to explicitly disclose wherein the correcting the motion of the at least one object comprises performing warping of at least one frame of the plurality of image frames along at least one axis based on the trajectory of the ground plane; obtaining a first correction value based on the warping, wherein the first correction value indicates shifting of the plurality of key points of the at least one object; and correcting the motion of the at least one object based on the first correction value; wherein the warping comprises transforming one or more geometric properties of at least one frame of the plurality of image frames. Rowell teaches the correcting the motion of the at least one object comprises performing warping of at least one frame of the plurality of image frames along at least one axis based on the trajectory of the ground plane (¶ [85]); obtaining a first correction value based on the warping (¶ [85]), wherein the first correction value indicates shifting of the plurality of key points of the at least one object (¶ [150-152]); and correcting the motion of the at least one object based on the first correction value (¶ [152] correcting direction); wherein the warping comprises transforming one or more geometric properties of at least one frame of the plurality of image frames (¶ [89] and ¶ [153] wherein rectification and warping transform the geometric properties of the frames). It would have been obvious to one of ordinary skill in the art before the invention was effectively filed for the method for recognizing an action of at least one object in a plurality of images as disclosed by Ma comprising obtaining a plurality of image frames and estimating a trajectory of a ground plane by tracking the motion of the ground plane to utilize the teachings of Rowell which teaches the correcting the motion of the at least one object comprises performing warping of at least one frame of the plurality of image frames along at least one axis based on the trajectory of the ground plane; obtaining a first correction value based on the warping, wherein the first correction value indicates shifting of the plurality of key points of the at least one object; and correcting the motion of the at least one object based on the first correction value; wherein the warping comprises transforming one or more geometric properties of at least one frame of the plurality of image frames to ensure the images are aligned and satisfy an epipolar geometry. Regarding claim 12, Ma discloses the apparatus of claim 8 (see rejection of claim 8), wherein the at least one processor is further configured, to correct the motion of the at least one object, to: perform warping of at least one frame of the plurality of image frames along at least one axis based on the trajectory of the ground plane (see rejection of claim 5); obtain a first correction value based on the warping, wherein the first correction value indicates shifting of the plurality of key points of the at least one object (see rejection of claim 5); and correct the motion of the at least one object based on the first correction value, wherein the warping comprises transforming one or more geometric properties of at least one frame of the plurality of image frames (see rejection of claim 5). Claims 4, 6, 11 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Ma in view of Dor Givon et al (US 20190130581 A1). Regarding claim 4, Ma discloses the method of claim 1 (see rejection of claim 1). Ma fails to explicitly disclose wherein the estimating the trajectory of the ground plane comprises detecting a location and a boundary of a plane surface of the ground plane in each of the plurality of image frames; determining a motion of the plane surface based on a comparison of the location and the boundary of the plane surface in the plurality of image frames; and estimating a trajectory of the plane surface by tracking the motion of at least one object. Givon et al, in the same field of endeavor of object tracking to characterize actions of human individuals in image scenes (¶ [12]), teaches estimating the trajectory of the ground plane comprises detecting a location and a boundary of a plane surface of the ground plane in each of the plurality of image frames (¶ [55]); determining a motion of the plane surface based on a comparison of the location and the boundary of the plane surface in the plurality of image frames (¶ [43-45]); and estimating a trajectory of the plane surface by tracking the motion of at least one object (¶ [43]). It would have been obvious to one of ordinary skill in the art before the invention was effectively filed for the method for recognizing an action of at least one object in a plurality of images as disclosed by Ma comprising obtaining a plurality of image frames and estimating a trajectory of a ground plane by tracking the motion of the ground plane to utilize the teachings of Givon which teaches estimating the trajectory of the ground plane comprises detecting a location and a boundary of a plane surface of the ground plane in each of the plurality of image frames; determining a motion of the plane surface based on a comparison of the location and the boundary of the plane surface in the plurality of image frames; and estimating a trajectory of the plane surface by tracking the motion of at least one object to accurately detect and characterize actions and recognize specific human individuals based on motion by compensating for distortions in image capture. Regarding claim 6, Ma discloses the method of claim 1 (see rejection of claim 1). Ma fails to explicitly disclose wherein the correcting the motion of the at least one object comprises detecting a location and a boundary of at least one static object in the plurality of image frames; estimating a trajectory of the at least one static object based on a comparison of the location and the boundary in the plurality of image frames; and correcting the motion of the at least one object in the plurality of image frames based on the estimated trajectory of the at least one static object. Givon et al teaches correcting the motion of the at least one object comprises detecting a location and a boundary of at least one static object in the plurality of image frames (¶ [51]); estimating a trajectory of the at least one static object based on a comparison of the location and the boundary in the plurality of image frames (¶ [51-52]); and correcting the motion of the at least one object in the plurality of image frames based on the estimated trajectory of the at least one static object (¶ [43]). It would have been obvious to one of ordinary skill in the art before the invention was effectively filed for the method for recognizing an action of at least one object in a plurality of images as disclosed by Ma comprising obtaining a plurality of image frames and estimating a trajectory of a ground plane by tracking the motion of the ground plane to utilize the teachings of Givon et al which teaches correcting the motion of the at least one object comprises detecting a location and a boundary of at least one static object in the plurality of image frames; estimating a trajectory of the at least one static object based on a comparison of the location and the boundary in the plurality of image frames; and correcting the motion of the at least one object in the plurality of image frames based on the estimated trajectory of the at least one static object to increase accuracy of detection of objects in scenes and compensate for possible distortions in image capturing. Regarding claim 11, Ma discloses the apparatus of claim 8 (see rejection of claim 8), wherein the at least one processor is further configured, to estimate the trajectory of the ground plane, to: detect a location and a boundary of a plane surface of the ground plane in each of the plurality of image frames (see rejection of claim 4); determine the motion of the plane surface based on a comparison of the location and the boundary of the plane surface in the plurality of image frames (see rejection of claim 4); and estimate the trajectory of the plane surface by tracking the motion of at least one object (see rejection of claim 4). Regarding claim 13, Ma discloses the apparatus of claim 8 (see rejection of claim 8), wherein the at least one processor is further configured, to correct the motion of the least one object, to: detect a location and a boundary of at least one static object in the plurality of image frames (see rejection of claim 6); estimate a trajectory of the at least one static object based on a comparison of the location and the boundary in the plurality of image frames (see rejection of claim 6); and correct the motion of the at least one object in the plurality of image frames based on the estimated trajectory of the at least one static object (see rejection of claim 6). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAMARES Q WASHINGTON whose telephone number is (571) 270-1585. The examiner can normally be reached Mon-Fri 8:30am-4:30pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Akwasi M. Sarpong can be reached at (571) 270-3438. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /JAMARES Q WASHINGTON/Primary Examiner, Art Unit 2681 September 17, 2026
Read full office action

Prosecution Timeline

Nov 13, 2024
Application Filed
Sep 21, 2026
Non-Final Rejection mailed — §101, §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
81%
Grant Probability
93%
With Interview (+11.4%)
2y 6m (~8m remaining)
Median Time to Grant
Low
PTA Risk
Based on 699 resolved cases by this examiner. Grant probability derived from career allowance rate.

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