PTAB

IPR2015-00940

LG Electronics Inc v. Mondis Technology Ltd

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1. Case Identification

2. Patent Overview

  • Title: Method for a Display Unit Displaying Video Signals Sent by a Video Source
  • Brief Description: The ’342 patent describes a method where a display unit communicates stored information, including an identification number, to an external video source (e.g., a computer) over a bi-directional communication link. This allows the video source to identify the display and configure settings appropriately.

3. Grounds for Unpatentability

Ground 1: Anticipation over Lien - Claims 14-15 are anticipated by Lien under 35 U.S.C. §102(e).

  • Prior Art Relied Upon: Lien (Patent 5,386,567).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lien discloses every limitation of claims 14 and 15. Lien teaches a system for "hot plugging" peripheral devices, including LCD display units, into a computer. Lien’s adapter, which can be integrated into the display, contains an “attribute information store” (a memory) that stores an “adapter identity (ID) information” and other configuration data (e.g., driver information). This information is communicated bi-directionally between the display adapter and the computer (the video source) upon connection, allowing the computer to identify the display type and configure itself accordingly. This disclosure was asserted to meet the claim requirements for communicating stored display unit information, including an identification number, over a bi-directional link.

Ground 2: Obviousness over Lien and I²C Standards - Claims 14-15 are obvious over Lien in view of I²C EEPROM and I²C Bus Specification under 35 U.S.C. §103.

  • Prior Art Relied Upon: Lien (Patent 5,386,567), I²C EEPROM (a 1989 Philips Components publication), and I²C Bus Specification (a 1992 Philips publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Lien teaches all elements of the claims. However, should the Board find Lien does not explicitly disclose a bi-directional communication link for transmitting the stored information, this feature is rendered obvious by the I²C references. The I²C EEPROM publication describes an EEPROM with control logic for sending and receiving messages over a two-line bi-directional I²C bus. The I²C Bus Specification further details this protocol as a low-cost, standard method for connecting peripherals to a host computer.
    • Motivation to Combine: A POSITA would combine the teachings because Lien and the I²C references address the same problem: connecting peripherals to a host computer. Since Lien does not specify the exact bus protocol or memory composition, a POSITA would have found it an obvious design choice to implement Lien’s “attribute information store” and communication bus using the well-known, low-cost, and functionally rich I²C standard. The I²C standard provided known benefits for designers and manufacturers, such as multi-master capability and arbitration, which Lien also required.
    • Expectation of Success: A POSITA would have a high expectation of success, as implementing a standard, commercially available memory and bus protocol like I²C into the peripheral connection system described by Lien would be a straightforward integration of known technologies for their intended purposes.

Ground 3: Anticipation over Welk - Claims 14-15 are anticipated by Welk under 35 U.S.C. §102(b).

  • Prior Art Relied Upon: Welk (Patent 4,549,172).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Welk, which describes a multicolor display compatible with different computer control units, discloses all claim limitations. Welk’s display station includes a memory (RAM) that stores a “terminal ID” identifying the type of display station. Upon power-on, a microprocessor in the display sends this ID data to the remote computer control unit (the video source). This communication is bi-directional, as the microprocessor is capable of both sending the ID and receiving signals from the control unit. Welk also discloses storing “extended attributes” (e.g., color information) in the memory in addition to the terminal ID, thus teaching the limitations of claim 15.

  • Additional Grounds: Petitioner asserted additional anticipation challenges under §102(b) based on Baji (Patent 5,027,400) and Tompkins (Patent 4,710,917), which were argued to similarly disclose all limitations of claims 14 and 15.

4. Key Claim Construction Positions

  • Petitioner argued for applying claim constructions adopted by the district court in a prior litigation. Key adopted constructions included:
    • "identification number": "a number that can be used to identify a display unit."
    • "display unit information": Construed under its plain and ordinary meaning.
  • These constructions were presented as sufficient to show that the prior art met the claim limitations without needing further interpretation.

5. Arguments Regarding Discretionary Denial

  • The petition was filed more than one year after an initial infringement complaint was served in 2008, but that complaint was later dismissed. A new complaint was served in 2014, less than a year before the petition filing.
  • Petitioner argued that the one-year time bar of §315(b) should not apply. It contended that the statute refers to "a complaint," not necessarily the "first complaint," and that a dismissal without prejudice for certain products leaves the parties as if the complaint had never been served for those products. Petitioner argued that fairness and public policy support allowing the IPR to proceed, as the Patent Owner was permitted to re-assert the patent in the new lawsuit.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 14 and 15 of the ’342 patent as unpatentable.