PTAB

IPR2015-00939

LG Electronics Inc v. Mondis Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Display Apparatus and Method for Controlling the Same
  • Brief Description: The ’588 patent describes a display apparatus that can be adjusted by an external computer. The invention purports to solve the problem of requiring a user to physically interact with adjustment switches on the display unit by enabling control of display properties, such as brightness and position, via signals from a separate computer.

3. Grounds for Unpatentability

Ground 1: Obviousness over Takahashi - Claim 1 is obvious over Takahashi

  • Prior Art Relied Upon: Takahashi (Japanese Published Patent Application H4-37787).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Takahashi discloses the core elements of claim 1 by teaching a system for adjusting display parameters (e.g., screen size, brightness) of a display device using a separate personal computer (PC). Takahashi’s display device includes a receiver (I/O Interface 22) and a CPU (20) that receives and processes control signals from the external PC. Petitioner contended that a person of ordinary skill in the art (POSITA) would have understood that the CPU inherently requires a memory to store instructions and data to perform its control functions.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the motivation was to implement the inherent or obvious modifications. Petitioner asserted it would have been obvious to a POSITA to incorporate an acknowledgment signal within Takahashi’s I/O interface. Conventional digital interfaces of the time included handshaking mechanisms to control data flow, and adding a feedback signal was a well-known method to ensure reliable communication between the PC and the display.
    • Expectation of Success: A POSITA would have a high expectation of success in adding a standard handshaking protocol to an I/O interface to improve reliability, as this was a common and predictable design choice.
    • Key Aspects: Petitioner emphasized that during a prior inter partes reexamination, the Board of Patent Appeals and Interferences (BPAI) twice rejected claim 1 as being obvious over Takahashi.

Ground 2: Anticipation by Tompkins - Claim 1 is anticipated by Tompkins

  • Prior Art Relied Upon: Tompkins (Patent 4,710,917).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Tompkins, which describes a video conferencing terminal ("Mate"), discloses every limitation of claim 1. The Mate is a display apparatus comprising a CPU (48), memory (50), and an interface (SCM multiplexer 51). The Mate receives control signals from an external computer (a remote Mate) via the interface, including a "Request for an Incoming Call." In response, the receiving Mate transmits an "Accept response," which Petitioner argued is the claimed "acknowledge signal." The memory stores the programs that enable the CPU to process these signals and control the display, fulfilling all claim elements.

Ground 3: Obviousness over Sawdon in view of Tompkins - Claim 1 is obvious over Sawdon in view of Tompkins

  • Prior Art Relied Upon: Sawdon (EP 0 456 923) and Tompkins (Patent 4,710,917).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Sawdon discloses a display apparatus with non-volatile memory for storing display information and a receiver for processing control signals (e.g., a "read command") from an external display adapter. Critically, Sawdon explicitly teaches a bidirectional "Handshaking" mode where the display device sends an "acknowledgement code" back to the external adapter. While Sawdon describes separate communication links for video/sync and control data, Tompkins teaches an integrated interface (a single cable multiplexer) that combines video, control, and other signals over a single cable.
    • Motivation to Combine: A POSITA would combine Sawdon’s handshaking and memory control with Tompkins’s integrated interface to create a simpler, more cost-effective, and more convenient system. Using a single coaxial cable as taught by Tompkins, instead of the multiple external wires suggested in Sawdon, was a known design choice for reducing cost and complexity in video display systems.
    • Expectation of Success: Combining a known interface type (Tompkins) with a known display control system (Sawdon) would have yielded predictable results.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 1 over Webb (Patent 5,216,504) in view of the RS-232C standard, arguing that Webb's monitor control system, which uses an RS-232 interface, would have been obviously combined with the known handshaking and acknowledgment protocols of the RS-232C standard.

4. Key Claim Construction Positions

  • Petitioner argued that the claim terms "external computer" and "software for operating said external computer" do not affirmatively limit the structure of the claimed display apparatus. Citing a BPAI decision from the prior reexamination, Petitioner contended these terms merely recite the source of signals the display apparatus is capable of receiving. Therefore, the structure of the external computer itself should not be given patentable weight when assessing the novelty or non-obviousness of the claimed display apparatus.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the petition was not time-barred under 35 U.S.C. §315(b), despite a prior patent infringement complaint being served in 2008. Petitioner contended that the 2008 complaint was dismissed without prejudice as to the currently accused products. It argued that such a dismissal leaves the parties in the same legal position as if the complaint had never been served. Further, Petitioner argued the plain language of the statute refers to "a complaint," not the "first complaint," making the petition timely filed within one year of a second complaint served in 2014.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claim 1 of the ’588 patent as unpatentable.