PTAB

IPR2014-01302

LG Electronics Inc v. Cypress Semiconductor Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for Selecting a Keyboard Key
  • Brief Description: The ’015 patent discloses an apparatus and method for a capacitance sensing device, such as a virtual keyboard, that reduces the required number of sensor elements. The purported inventive concept involves assigning multiple pre-defined key areas to at least a single shared sensor element.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, 4, and 6 by Hristov

  • Prior Art Relied Upon: Hristov (Patent 7,821,502).
  • Core Argument for this Ground: Petitioner argued that Hristov, a reference considered during prosecution, fully discloses every limitation of the challenged claims. The Examiner allegedly failed to appreciate that Hristov teaches the key limitation added for allowance: a single sensor element corresponding to multiple pre-defined key areas.
    • Prior Art Mapping: Petitioner asserted that Hristov’s position sensor, which includes a display screen overlaid on a pattern of sensing electrodes, meets the limitations of independent claim 1. Hristov’s Figure 6 shows a menu of commands (e.g., number keys 0-9) that function as a “plurality of keyboard keys” assigned to “pre-defined areas” on a “sensing surface.” Petitioner contended that an annotated version of Hristov’s Figure 6 clearly shows a single, continuous sensor element that underlies both the “1” and “5” keys, thereby explicitly teaching the limitation “wherein at least one of the plurality of sensor elements corresponds to multiple pre-defined areas.” Furthermore, Hristov was argued to teach determining a conductive object’s position by measuring capacitance via processing circuitry and selecting the corresponding key by comparing the touch position to the pre-defined key areas. Dependent claims 2, 4, and 6 were also allegedly taught by Hristov's disclosure of comparing touch position to key areas, outputting data to an external host controller, and arranging keys and sensors in multiple rows.

Ground 2: Obviousness of Claims 1, 2, 4-7, 13, 17-19, 21, and 22 over Boie and Andre

  • Prior Art Relied Upon: Boie (Patent 5,463,388) and Andre (Patent 7,844,914).

  • Core Argument for this Ground: Petitioner argued that Boie teaches the fundamental architecture of a capacitance sensing keyboard where fewer sensors are used than keys, and Andre provides teachings on virtual keyboard layouts for modern handheld devices that would have made the claimed invention obvious.

    • Prior Art Mapping: Boie was presented as teaching a capacitive position sensor used as a keyboard, as shown in its Figure 7. This figure depicts a keyboard with 17 buttons superimposed on a 4x4 grid of 16 sensor electrodes. Petitioner argued this configuration inherently discloses the key limitation of "at least one of the plurality of sensor elements correspond[ing] to multiple pre-defined areas," since there are more keys than sensor elements. Boie also taught determining the touched key by measuring capacitance at each electrode, calculating the centroid of the touch, and comparing its coordinates to pre-defined ranges stored for each key. Andre was cited for its disclosure of virtual keyboard layouts, including hexagonal and arc-shaped keys, designed to improve thumb activation on handheld devices where a user’s thumb is relatively large and difficult to control.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Andre’s teachings on ergonomic virtual key layouts for handheld devices with Boie’s established capacitance sensing keyboard technology. The combination would address the known problem of accurately activating keys on a small, handheld device, particularly with a thumb, thereby enhancing the user's ability to operate the device. Petitioner asserted that Boie and Andre are complementary references addressing virtual keys, layout, and sensing.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these technologies as both relate directly to user input on electronic devices and involve no technical incompatibility.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 5, 7, 13, 15, 17-19, 21, and 22 are obvious over Hristov alone, and that claim 15 is obvious over the combination of Boie, Andre, and Hristov. These arguments relied on extending the core teachings of the primary references, such as Hristov’s disclosure of use in a mobile phone, to meet further dependent claim limitations.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1, 2, 4-7, 13, 15, 17-19, 21, and 22 of the ’015 patent as unpatentable.