PTAB

IPR2018-00985

Samsung Electronics Co Ltd v. Keynetik Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Motion-Based Device Control
  • Brief Description: The ’146 patent discloses a system that uses an accelerometer to sense a device's motion and generate corresponding commands for a user interface. The invention centers on a "step motion algorithm" that introduces a temporary "sleep period" or insensitivity timeout after a command is executed, preventing further motion input until a "wake up" command re-activates the motion sensing.

3. Grounds for Unpatentability

Ground 1: Claims 22 and 23 are anticipated by Liberty under 35 U.S.C. §102.

  • Prior Art Relied Upon: Liberty (Patent 7,535,456).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Liberty, which teaches methods for removing unintentional movement in 3D pointing devices, discloses every limitation of the challenged claims. Liberty describes a handheld pointing device with an accelerometer that translates physical movement into user interface commands, meeting the requirements of the claimed "motion input algorithm." The core of the anticipation argument centered on Liberty’s technique for "fine mode clicking." This technique suppresses or discards unintentional motion data immediately following a user action, such as a button press, to improve targeting accuracy. Petitioner asserted this data suppression is the claimed "sleep command." Liberty further teaches that this suppression lasts until a time threshold is exceeded, at which point normal operation resumes. Petitioner mapped this resumption to the claimed instructions to "re-activate the motion sensing algorithm" after a defined period. Dependent claim 23, which requires the sleep command to "temporarily block" new commands, was argued to be inherently disclosed by Liberty’s data suppression function.
    • Key Aspects: The argument equated Liberty’s technical solution for filtering user-induced jitter during a button press with the ’146 patent’s specific algorithmic structure of "sleep" and "re-activate" commands.

Ground 2: Claims 22 and 23 are obvious over Noguera in view of Liberty under 35 U.S.C. §103.

  • Prior Art Relied Upon: Noguera (Patent 6,847,351) and Liberty (Patent 7,535,456).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Noguera provides the basic framework of the claimed invention. Noguera discloses a handheld device with an accelerometer (a "tilt sensor") and a controller that translates device orientation into pointer commands on a display, thus teaching a "motion input algorithm." Noguera also teaches a filtering technique using a defined "delay period" where pointer updates are paused to avoid registering unintentional movement, effectively creating a sleep state. However, Petitioner argued Noguera does not explicitly teach initiating this state with a "sleep command" triggered after a user command is executed (e.g., positioning a cursor). Liberty was introduced to supply this missing element. Liberty expressly teaches suppressing motion data subsequent to a detected user event, such as a button click, to prevent errant cursor movement.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would be motivated to combine these references to solve a known and common problem: pointer instability caused by the physical act of clicking a button on a motion-controlled device. A POSITA would look to a solution like Liberty’s—which is designed to enhance precision during such actions—and apply it to Noguera’s system. This modification would be a predictable improvement, consistent with Noguera's stated goal of filtering unintentional movement to make the pointer more reliable.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination. Both references address the same technical challenge in the same field of motion-based input control. Integrating Liberty’s software-based filtering logic into Noguera’s device controller would have involved nothing more than straightforward programming to achieve the predictable result of a more stable and accurate pointing device.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 22 and 23 of the ’146 patent as unpatentable.