PTAB

IPR2016-00908

Samsung Electronics Co Ltd v. Uusi LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Capacitive Responsive Electronic Switching Circuit
  • Brief Description: The ’183 patent discloses a capacitive touch switching circuit. The circuit uses an oscillator to provide a periodic signal to a touch terminal; when an operator's touch increases the capacitance at the terminal, a detector circuit generates a control signal to actuate a device.

3. Grounds for Unpatentability

Ground 1: Claims 37-41, 43, 45, 61, 64-67, 69, 83, 85, 86, 88, 90, 91, 94, 96, 97, 99, 101, and 102 are obvious over the combination of Ingraham I, Caldwell, and Gerpheide.

  • Prior Art Relied Upon: Ingraham I (Patent 5,087,825), Caldwell (Patent 5,594,222), and Gerpheide (Patent 5,565,658).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ingraham I teaches the foundational capacitive touch keyboard system, including a touch plate assembly, control circuit, and microcontroller that detects a change in capacitance-to-ground when a user touches an input. However, Ingraham I relies on an external AC power source for its oscillating signal. Petitioner contended that Caldwell, which discloses a touch panel with a dedicated oscillator and an efficient matrix scanning mechanism, supplies the missing elements. The combination of Ingraham I and Caldwell’s scanning architecture (using a microcontroller to control demultiplexers and multiplexers) was asserted to teach the claimed selective provision of signals to a keypad array. To address claim limitations requiring the use of multiple "frequencies," Petitioner introduced Gerpheide, which explicitly teaches varying the oscillator frequency to find one with the lowest electrical interference, thereby improving system reliability.
    • Motivation to Combine: A POSITA would combine Ingraham I with Caldwell for two primary reasons: first, to adapt Ingraham I’s system for portable applications (e.g., in an automobile) where an AC wall outlet is unavailable, necessitating a dedicated oscillator as taught by Caldwell. Second, a POSITA would incorporate Caldwell’s efficient matrix scanning technique to reduce the number of I/O pins required on the microcontroller and simplify wiring, which are known design constraints. A POSITA would then be further motivated to add the teachings of Gerpheide to this combined system to address the known problem of electrical interference in capacitive sensors, a solution Gerpheide provides by varying signal frequencies.
    • Expectation of Success: Petitioner asserted the combination involved applying known techniques to similar systems to achieve predictable results. Each reference’s components would perform their known functions in the combined system, resulting in a more compact, efficient, and interference-resistant capacitive touch device.

Ground 2: Claims 47, 48, 62, 63, and 84 are obvious over the combination of Ingraham I, Caldwell, Gerpheide, and Wheeler.

  • Prior Art Relied Upon: Ingraham I (Patent 5,087,825), Caldwell (Patent 5,594,222), Gerpheide (Patent 5,565,658), and Wheeler (Patent 5,341,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Ingraham I-Caldwell-Gerpheide combination from Ground 1 and adds the teachings of Wheeler to address limitations in a smaller set of dependent claims. Petitioner argued that these claims require comparing a sensed capacitance change to a second threshold level. Wheeler discloses an industrial control system with capacitive proximity switches that, for safety reasons, requires an operator to activate two switches in sequence within a specific time interval to actuate a machine. Petitioner contended that implementing this two-step activation logic into the base combination would meet the "second threshold" limitation, as the system logic would only generate a final control output after detecting two distinct touch events, each crossing its own threshold.
    • Motivation to Combine: A POSITA would be motivated to incorporate Wheeler's teachings to adapt the base capacitive touch system for use in environments with heightened safety requirements, such as industrial machine control. Wheeler directly addresses the need for preventing accidental machine operation by requiring sequential switch activation, providing a clear reason to add this functionality to the system from Ground 1.
    • Expectation of Success: Adding a sequential activation safety logic as taught by Wheeler was presented as a predictable modification that would allow the combined system to operate safely in industrial environments, which was a common-sense implementation for a skilled artisan.

4. Key Claim Construction Positions

  • "input touch terminals": Petitioner proposed construing this term as "a plurality of distinct touch pads of permanent and fixed location configured to allow detection of an operator's input only by a detector circuit or circuits." This construction was argued to be necessary to show that the physically distinct and fixed input portions of the Ingraham I keyboard meet the claim language.
  • "detector circuit": Petitioner proposed the construction "an electronic circuit, separate from the microcontroller and the oscillator, that detects an increase in capacitance to ground." This construction was used to distinguish the touch sensing circuits in Ingraham I from the system's microcontroller, mapping Ingraham I's architecture onto the claimed elements.
  • "responsive to a presence of an operator's body capacitance to ground": Petitioner argued this should be construed as "responsive to an increase in capacitance caused by the operator's body." This specificity was used to align the claim language with the physical phenomenon described in Ingraham I, where a touch increases capacitance, which in turn triggers the detector circuit.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 37-41, 43, 45, 47, 48, 61-67, 69, 83-86, 88, 90, 91, 94, 96, 97, 99, 101, and 102 of the ’183 patent as unpatentable.