PTAB

IPR2015-00043

ASUSTeK Computer Inc v. ExoTablet Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Handheld Input/Output Device Providing Enhanced User Interface for a Mobile Telephone
  • Brief Description: The ’919 patent relates to an input/output device accessory for a mobile telephone. The device is intended to overcome the limitations of early mobile phones by providing a larger display screen and more user-friendly input components (e.g., a keyboard) when mated with the phone.

3. Grounds for Unpatentability

Ground 1: Anticipation or Obviousness over Chitturi - Claims 1-4, 6, 7, 14, and 19 are anticipated under 35 U.S.C. §102 or, in the alternative, obvious under §103 over Chitturi, alone or in view of other references.

  • Prior Art Relied Upon: Chitturi (Patent 6,489,932), Qualcomm (a 1999 CNN.com article), Kyocera (a 2000 Forbes.com article), Kahn (Patent 6,505,055), Silvester (Patent 7,010,634), Yang (Patent 6,184,652), and Hennig (Patent 5,514,995).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chitturi discloses every element of the challenged claims. Chitturi teaches a handheld "display device" (in tablet or notebook form factors) with an integral "docking station" for receiving a "palm sized computing device." Petitioner asserted this "display device" is the claimed "input/output device" and the docking station is the claimed "cradle." A central contention was that a person of ordinary skill in the art (POSITA) at the time would have understood Chitturi's "palm sized computing device" to encompass mobile phone/PDA combination devices, citing contemporary Qualcomm and Kyocera products that integrated Palm Pilot functionality with a cellular phone.
    • Chitturi's device includes a flat panel display explicitly described as larger than the docked computing device's screen, satisfying the "larger...display screen" limitation of independent claim 1. It also discloses user-operable input devices—a touchscreen for the tablet version and a keyboard/cursor control for the notebook version—to control the docked device. The "communication port" of claim 1 is met by Chitturi's communication interface (110) that enables communication between the display device and the docked computing device.
    • Petitioner systematically mapped Chitturi to the dependent claims. The overall system provides an "enhanced user interface" (claim 2) by offering a "more comfortable experience." Chitturi's inclusion of a microcontroller (102), memory (104), and storage media meets the requirements for a processor and data storage device (claim 3). The tablet embodiment's touch-sensitive display satisfies the touchscreen limitation (claim 4), while the notebook embodiment’s keyboard (122) meets claim 6. For claim 7, Chitturi's internally disposed docking station forms a "channel" that receives and "conceals" the mobile device from view. Finally, Chitturi explicitly states that information from the mobile device is displayed on the larger screen, meeting claim 19.
    • Motivation to Combine (for §103 grounds): For its alternative obviousness argument against claim 14 (requiring a power source to power both devices), Petitioner asserted a clear motivation. A POSITA would have sought to solve the well-known problem of limited battery life in portable electronics. Modifying Chitturi’s docking system to transfer power from the larger, host device to the smaller, docked mobile device would be a logical step to increase the mobile device's usability and the overall product's marketability. This was not a novel idea, but rather a common-sense solution to a known problem.
    • This motivation is confirmed by references like Kahn and Silvester. Kahn teaches an organizer accessory that mates with and provides auxiliary power to a telephone. Silvester is even more direct, disclosing a notebook or tablet computer with its own battery (power supply 250) that explicitly "may be used to charge battery 255" of a docked PDA.
    • Expectation of Success: A POSITA would have had a high expectation of success. The constituent parts—a docking display (Chitturi), a power-transfer mechanism (Kahn, Silvester), and standard power/data interfaces (Yang, Hennig)—were all known, well-understood, and proven to work. Combining them would involve applying known techniques to achieve a predictable result.

4. Key Claim Construction Positions

  • The petition argued for the "broadest reasonable interpretation" for several key terms, asserting these constructions were critical for its invalidity contentions.
  • "cradle": Proposed as simply "a mechanical support." This broad construction was important because it allowed Chitturi's "docking station 108," which mechanically receives and supports the palm-sized computer, to meet the limitation without requiring any specific shape or feature beyond physical support.
  • "channel": Argued to take its plain and ordinary meaning. By avoiding a narrow definition, the petition contended that the structure of Chitturi's docking station, described with walls forming a receiving area, inherently defines a channel for the mobile device.
  • "concealed": Proposed as "hidden from sight." This straightforward construction is directly met by Chitturi's primary embodiments where the docked computing device is fully enclosed within the housing of the larger display device, rather than being partially visible.
  • "power source": Construed broadly as "a source of power including any connection for connecting to a power outlet." This interpretation was central to the obviousness argument for claim 14. It allowed prior art that taught power transfer from a host device's internal battery (like in Silvester) to satisfy the limitation, not just power from an external wall outlet.

5. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel claims 1, 2, 3, 4, 6, 7, 14, and 19 of Patent 7,477,919 as unpatentable.