PTAB

IPR2018-01664

Samsung Electronics America Inc v. Uniloc 2017 LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Waking a Device Using Motion Detection
  • Brief Description: The ’646 patent discloses a system for waking a mobile device from a low-power inactive state in response to detected motion. The system uses a motion sensor to establish an "idle sample value" while at rest and then detects a change along a "dominant axis" (the axis most affected by gravity) to trigger a transition back to an active state.

3. Grounds for Unpatentability

Ground 1: Claim 22 is obvious over Pasolini in view of Goldman, McMahan, Mizell, and Park.

  • Prior Art Relied Upon: Pasolini (Patent 7,409,291), Goldman (Sun Microsystems publication, Feb. 2007), McMahan (Patent 7,204,123), Mizell (IEEE Symposium paper, 2003), and Park (Patent 7,028,220).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the prior art combination taught every limitation of claim 22, which depends from independent claim 20.
      • Base System (Claim 20): Petitioner asserted that Pasolini taught the foundational system of a portable electronic device using a multi-axis accelerometer to detect motion (e.g., being picked up) and wake from a standby mode. Petitioner argued that Pasolini discloses detecting acceleration along the axis most aligned with gravity, thereby teaching the "dominant axis" concept.
      • Glitch Correction: McMahan was added for its teaching of enhancing sensor accuracy by identifying and removing anomalous data points ("glitches") that fall outside an expected range. The combination would incorporate this technique to improve the reliability of the accelerometer data from Pasolini.
      • Idle Value & Dominant Axis Logic: Goldman was added for its disclosure of programmatic methods for processing accelerometer data. Specifically, Goldman taught computing a rest offset value ("idle sample value") by sampling acceleration on all three axes while a device is at rest to zero out the force of gravity. Because Goldman samples all axes, it inherently captures data from the dominant axis.
      • Averaging: Mizell was added for its teaching of averaging accelerometer samples over a sampling interval to reduce signal noise and obtain a more accurate representation of the gravity component. This would be applied to the idle sample value calculated using Goldman's methods.
      • State Restoration (Claim 22): Park was added to teach the final limitation of claim 22: "device state logic to restore the device to... a last active state." Park disclosed a portable system that saves system status data before entering a suspend mode and uses that data to restore the system to its prior state upon waking.
    • Motivation to Combine: Petitioner asserted several motivations for the combination. A POSITA would combine Pasolini with Goldman to implement more robust, flexible, and accurate accelerometer features. A POSITA would incorporate McMahan's glitch removal and Mizell's signal averaging as known techniques to improve the accuracy and reliability of any accelerometer-based system. Finally, a POSITA would incorporate Park’s state-restoration feature into the combined device to enhance user convenience, a well-known objective for portable electronics. Each step was presented as applying a known technique to improve a similar device in a predictable way.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because each added technique was well-known in the art for improving portable electronic devices. Furthermore, the techniques taught by Goldman, McMahan, Mizell, and Park were readily implementable with software in the hardware system described by Pasolini.
    • Key Aspects: Petitioner noted that the Board had already instituted review in a related case (IPR2018-00289) on the base claim 20 and a similar dependent claim 18, based on the same prior art combination and arguments presented here.

4. Key Claim Construction Positions

  • "glitch": Petitioner proposed this term be construed as "a datum that is outside of an acceptable range," based on the patent's specification.
  • "a change in the dominant axis": Petitioner argued this phrase should be interpreted as "at least a change in acceleration measured along the dominant axis," based on intrinsic evidence.
  • "logic" terms (e.g., "dominant axis logic," "power logic," "device state logic"): Petitioner presented two alternative construction approaches.
    • The primary proposal was a broad construction of "hardware, software, or both that performs the recited function."
    • Alternatively, Petitioner argued that if the terms were construed under 35 U.S.C. §112, sixth paragraph (means-plus-function), the prior art still disclosed corresponding structures (e.g., Pasolini's control unit, Goldman's software methods) that perform the claimed functions. Petitioner asserted the claims were obvious under either construction.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claim 22 of the ’646 patent as unpatentable.