PTAB

IPR2019-00030

Apple Inc v. Corephotonics Ltd

Key Events

Petition

petition

Title: Five-Element Telephoto Lens Assembly
Brief Description: The ’568 patent discloses a compact, five-element telephoto lens assembly designed for high-quality imaging in portable electronic devices. The invention is characterized by specific optical parameters, including a total track length (TTL) to effective focal length (EFL) ratio of less than 1.0, and a defined ratio between the center thickness and edge thickness of the first lens element.

Prior Art Relied Upon: Ogino (Patent 9,128,267).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Ogino’s “Example 6” embodiment, which describes a five-lens imaging system for portable devices, discloses every limitation of the challenged claims. Petitioner asserted Ogino teaches a lens assembly with aspheric surfaces, a TTL of 4.387 mm (less than the claimed 6.5 mm), an EFL of 4.428 mm, a resulting TTL/EFL ratio of 0.9907 (less than 1.0), and an F-number of 2.64 (smaller than 3.2). For the final limitation—a ratio between the first lens’s largest optical axis thickness (L11) and circumferential edge thickness (L1e) of less than 4.0—Petitioner contended that a person of ordinary skill in the art (POSITA) would calculate this ratio to be as low as 2.533 based on Ogino’s disclosed optical data and the necessary entrance pupil diameter. This calculation satisfies the limitations of independent claim 1 and dependent claims 2-5.
- Key Aspects: The central technical argument for this ground involved calculating the first lens's unspecified edge thickness by using Ogino's disclosed sag equation and deriving the necessary lens diameter from its stated F-number and focal length.

Prior Art Relied Upon: Ogino (Patent 9,128,267) and Beich (a 2010 SPIE publication titled “Polymer Optics: A manufacturer’s perspective...”).
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that Ogino teaches most claim limitations, consistent with Ground 1. Beich was introduced to reinforce the argument for the L11/L1e thickness ratio from a manufacturing standpoint. Beich provides "rules of thumb" for manufacturing polymer optics via injection molding, a process a POSITA would find suitable for Ogino's compact lens design.
- Motivation to Combine: A POSITA implementing Ogino’s optical design for a portable device would be motivated to use cost-effective manufacturing methods like plastic injection molding. In doing so, the POSITA would consult a reference like Beich for established manufacturing best practices and constraints.
- Expectation of Success: Beich explicitly teaches that for manufacturability, a lens’s center-to-edge thickness ratio should be less than 3:1 to avoid challenges in the molding process. A POSITA would have a reasonable expectation of success in applying this known manufacturing constraint to Ogino's design. This would predictably yield a functional lens that meets the claimed L11/L1e ratio limitation of less than 4.0 (and the stricter ratios of dependent claims 2-5), as it is a direct application of a standard design principle to improve manufacturability.

"Total Track Length (TTL)": Petitioner argued this term should be construed as "the length of the optical axis spacing between the object-side surface of the first lens element and the image plane." This construction was based on the patent’s specification and its consistency with the term’s ordinary meaning in the art.
"Effective Focal Length (EFL)": Petitioner asserted this term should be construed as "the focal length of a lens assembly," which is its well-known and accepted meaning to a POSITA.

Derivation of Edge Thickness (L1e) from Ogino: A core technical contention across multiple grounds was that a POSITA could and would derive the edge thickness of Ogino's first lens, even though it is not explicitly stated. Petitioner’s expert argued that a POSITA would first calculate the required entrance pupil diameter (1.6773 mm) from Ogino's disclosed focal length and F-number. This diameter would then serve as the minimum usable lens diameter. By inputting this diameter into Ogino’s provided "sag" equation, a POSITA could calculate the circumferential edge thickness (L1e) to be 0.2199 mm. This derived value, when compared to the disclosed center thickness (L11) of 0.557 mm, results in an L11/L1e ratio of 2.533, satisfying the claim limitation.

Petitioner requests the institution of an inter partes review (IPR) for claims 1-5 of the ’568 patent and the cancellation of these claims as unpatentable under 35 U.S.C. §103.