PTAB

IPR2017-00497

Crestron Electronics Inc v. Vesper Technology Research LLC

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1. Case Identification

2. Patent Overview

  • Title: Data Transfer System And Method For Multi-Level Signal Of Matrix Display
  • Brief Description: The ’247 patent discloses a system for transferring display data to a matrix liquid crystal display (LCD). The system purports to solve issues of high data rates and electromagnetic interference (EMI) by using multi-level signaling, where each data line on a bus can represent one of multiple states, thereby reducing the required number of data lines or the transfer frequency.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3 and 5 under 35 U.S.C. §102

  • Prior Art Relied Upon: Kim (Patent 6,339,622).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim discloses every element of the challenged claims. Kim teaches a data transmission device for an LCD that improves efficiency by converting binary data to ternary (three-level) data. This system inherently comprises a "multi-level timing controller" (Kim's LCD controller 47) that receives digital data and converts it to a multi-level output, a "multi-level signal bus" connecting the controller to drivers, and "multi-level input data drivers" (Kim's source drivers 43) that receive the multi-level signal. For dependent claims, Petitioner asserted Kim's system includes an encoder for converting binary to ternary data and a decoder for converting it back.

Ground 2: Obviousness of Claims 8-10 over Kim and Admitted Prior Art in view of Watanabe

  • Prior Art Relied Upon: Kim (Patent 6,339,622), Admitted Prior Art (“APA”) of the ’247 patent, and Watanabe (Patent 5,684,833).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Kim, in view of the APA, teaches the base system of a multi-level data transfer architecture for an LCD as recited in independent claims 1, 3, and 6. This ground specifically addresses the dependent claim limitation requiring the multi-level signal to be in the form of digital signals with "amplitudes equal to one of eight values." Petitioner argued Watanabe explicitly teaches a method for data transmission using a multi-level signal with eight distinct amplitude levels (representing 3-bit data) to improve accuracy and efficiency.
    • Motivation to Combine: A POSITA would combine these references as they address the same problem: improving data transmission efficiency by converting binary to multi-level signals. Applying Watanabe’s well-understood eight-level signaling scheme to Kim's three-level system was presented as a predictable design choice to further increase data throughput and efficiency, which was a known goal in the art.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing Kim’s system with the eight levels taught by Watanabe, as it amounted to using a known technique to improve a similar device in a predictable way.

Ground 3: Obviousness of Claims 1-7 over Go in view of Admitted Prior Art

  • Prior Art Relied Upon: Go (Patent 6,320,590) and APA of the ’247 patent.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Go as an alternative primary reference disclosing a data transfer system that uses multi-level signals to reduce the number of transmission lines for an LCD. Go's system features a "bus compressor" (a multi-level timing controller) that compresses 18-bit digital video data into 9 multi-level analog signals. These signals are sent over a bus to a "bus decompressor" (a multi-level input data driver) that reconstructs the digital video data. Petitioner contended that Go teaches the core components of the claimed system, with the APA providing the context of conventional LCD architecture.
    • Motivation to Combine: A POSITA seeking to solve the problem of reducing data transmission lines in an LCD driver, as described in the ’247 patent, would have been motivated to look at prior art like Go. Combining Go's specific multi-level signaling solution with the general, conventional LCD structures described in the APA was argued to be an obvious design approach.
    • Expectation of Success: A POSITA would have expected success because the combination involved applying Go's known data compression techniques to a standard LCD configuration, a straightforward integration of compatible technologies.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 1-7 being obvious over Kim in view of the APA, and claims 8-10 being obvious over Go and the APA in view of Cao (Patent 5,761,246). These grounds relied on similar arguments, with Cao being cited to teach an eight-level signaling scheme.

4. Key Claim Construction Positions

  • Petitioner argued that the term "Multi-level" should be construed to mean "having more than two possible meaningful levels." This proposed construction was based on the patent owner's own express admission and dictionary definition provided during prosecution to overcome a 35 U.S.C. §112 rejection, where the applicant asserted that multi-level signals and transmission were well understood by a POSITA.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10 of the ’247 patent as unpatentable.