PTAB

IPR2017-01381

Lenovo United States Inc v. Blackbird Tech LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multipurpose Computer Display System
  • Brief Description: The ’931 patent discloses a portable computer system featuring a display screen attached to a keyboard base via a dual-axis mounting assembly, allowing the screen to both pivot and rotate. A key aspect of the invention is the placement of an input/output port on the front wall of the keyboard base to facilitate connection with ancillary computer systems, particularly when the screen is rotated away from the primary user for viewing by others.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-3 and 8 over Wu in view of Kikinis

  • Prior Art Relied Upon: Wu (Patent 5,016,849) and Kikinis (Patent 5,708,840).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wu disclosed the core mechanical elements of independent claim 1, including a laptop computer with a keyboard base and a display screen connected by a mounting assembly that permits both rotational (vertical axis) and pivotal (horizontal axis) motion. Petitioner contended that Kikinis supplied the remaining limitations by teaching a host laptop computer that includes PCMCIA ports, at least one of which is located proximate the front wall of the keyboard base. Kikinis further taught that these ports could connect to an ancillary computer system, such as its disclosed micro PDA, and generate an image on the host computer's display.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would understand that Wu’s disclosure of a mechanical swivel mechanism was incomplete and would require standard hardware, like ports, to be a functional computer. A POSITA would combine Wu’s swivel hinge with the known port configurations taught by Kikinis to improve the working efficiency and practicality of the laptop. Placing a port on the front, as shown in Kikinis, was an obvious design choice to allow a user to easily connect ancillary devices while the screen was rotated for others to view.
    • Expectation of Success: A POSITA would have a high expectation of success as the combination involved integrating conventional, well-understood computer components (ports) into a known laptop structure, which constituted a predictable variation.

Ground 2: Obviousness of Claims 9 and 10 over Wu in view of Kikinis and Anderson

  • Prior Art Relied Upon: Wu (Patent 5,016,849), Kikinis (Patent 5,708,840), and Anderson (Patent 5,335,142).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Wu and Kikinis combination to address dependent claims 9 and 10. Petitioner argued Anderson taught the additional limitation of claim 9, which required "at least one stop for limiting rotational motion," by disclosing a hinge with stop tabs that limit rotation to a predetermined range. For claim 10, which required the rotatable element to be a "turret that is rotatable relative to a circular opening," Anderson allegedly taught this by disclosing a rotatable swivel disk (turret) that operates within a circular mounting ring affixed to the computer's base.
    • Motivation to Combine: A POSITA would be motivated to add Anderson’s rotational stops to the Wu/Kikinis combination to solve the known problem of preventing excessive twisting and potential damage to the internal communication cable connecting the display and base. This modification represented the application of a known technique to improve a similar device. Similarly, incorporating Anderson’s turret design was an obvious way to improve the integration of Wu’s swivel mechanism.
    • Expectation of Success: Integrating a known stop mechanism and a common turret design into a hinge assembly was a routine design choice with predictable results.

Ground 4: Obviousness of Claims 1 and 8 over Wu in view of Kumar

  • Prior Art Relied Upon: Wu (Patent 5,016,849) and Kumar (Patent 5,632,373).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative combination for claims 1 and 8, again starting with Wu for the dual-axis swivel mechanism. Petitioner argued that Kumar, which discloses a protective case for a portable computer, expressly taught the port-related limitations. Kumar disclosed that a portable computer is "normally provided with a plurality of input/output ports such as port 20 extending through front wall 9." Kumar also taught that such computers interact with various ancillary devices.
    • Motivation to Combine: A POSITA looking to create a complete, functional laptop based on Wu’s hinge design would have looked to references like Kumar for standard features. A POSITA would combine Wu’s hinge with Kumar’s explicit disclosure of front-facing ports to achieve the common design goal of improving the practicality and efficiency of connecting peripherals. This combination was a predictable variation of existing prior art elements from the same field.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations, including Wu in view of Kikinis and Ioka (to teach 180-degree rotation for claim 6), Wu in view of Kumar and Anderson (addressing claims 3, 9, and 10), and Wu in view of Kumar and Ioka (addressing claims 2 and 6).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. § 325(d) would be inappropriate. Although the examiner had cited Kikinis and Anderson during the original prosecution, Petitioner contended that the examiner did not substantively apply them in the specific combinations with Wu as presented in the petition. Therefore, the asserted grounds were new, not cumulative of the prosecution history, and warranted consideration on the merits.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6, and 8-10 of the ’931 patent as unpatentable under 35 U.S.C. § 103.