PTAB

IPR2019-00091

HTC Corp v. Lemaire Illumination Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Illumination Source With Controlled Output
  • Brief Description: The ’390 patent discloses a system for controlling light-emitting diodes (LEDs) whose output color is dependent on the level of driving current. The invention claims methods for controlling the LED’s color by adjusting the height (amplitude) of electrical pulses and controlling the LED’s brightness by adjusting the on-time proportion (e.g., pulse width or frequency) of the pulses.

3. Grounds for Unpatentability

Ground 1: Claims 19 and 22 are obvious over Mueller and Kaelin

  • Prior Art Relied Upon: Mueller (Patent 6,016,038) and Kaelin (Patent 3,909,788).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kaelin teaches the core invention of claim 19: an illumination source with a color-changing LED and a control circuit that uses pulse height modulation to control color and pulse width modulation to control brightness. Kaelin discloses using different current levels (pulse heights) to generate red, green, or yellow light and varying pulse widths to control the apparent brightness. To address the "housing" limitation of claim 19, Petitioner cited Mueller, which explicitly teaches a lighting system with an LED array contained within a housing.
    • Motivation to Combine: A POSITA would combine Kaelin's control system with Mueller's housing because a housing is a fundamental and necessary component for any finished electronic device. Petitioner contended that implementing Kaelin's LED display array within a physical housing, as taught by Mueller, would be an obvious and routine design step to create a complete, usable product and protect the internal circuitry.
    • Expectation of Success: The combination involved integrating a well-understood electronic control system into a standard mechanical enclosure. This was presented as a simple assembly with highly predictable results and no technical hurdles.

Ground 2: Claims 9 and 20 are obvious over Mueller, Kaelin, and Okino

  • Prior Art Relied Upon: Mueller (Patent 6,016,038), Kaelin (Patent 3,909,788), and Okino (Patent 4,847,680).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built on the Kaelin/Mueller combination to challenge claims requiring a "video camera imaging device" and a "feedback signal." Petitioner asserted that Okino teaches a camera system that uses a colorimetric sensor to provide a feedback signal for adjusting the color of its illumination source to achieve optimal white balance for image capture. The combination of Kaelin and Mueller provided the base LED illumination system, while Okino provided the claimed camera and feedback functionality.
    • Motivation to Combine: A POSITA seeking to improve the camera system in Okino would be motivated to incorporate a more modern and efficient light source, such as the color-controllable LED system taught by Kaelin. Okino established the need for automatic color adjustment in a camera's light source, and Kaelin provided an effective means to achieve it. Combining these known elements would improve image quality by actively managing the illumination color.
    • Expectation of Success: Integrating a known feedback loop (from Okino) to control a known adjustable light source (from Kaelin) was argued to be a straightforward application of conventional engineering principles with a high likelihood of success.

Ground 3: Claims 7, 8, 17, and 18 are obvious over Mueller, Okino, and Kitajima

  • Prior Art Relied Upon: Mueller (Patent 6,016,038), Okino (Patent 4,847,680), and Kitajima (Patent 5,808,681).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the feedback signal to be based on a "video output signal" from the imaging device itself, rather than a separate sensor. While Okino used a dedicated colorimetric sensor, Petitioner argued that Kitajima explicitly teaches that such a sensor can be omitted. Kitajima disclosed that color balance information can be measured directly from the image data captured by the CCD image sensor and processed by an image signal processor.
    • Motivation to Combine: A POSITA would combine Kitajima's teaching with the Okino/Mueller system to create a more integrated and cost-effective device. Kitajima provided a clear motivation to eliminate the external sensor taught by Okino in favor of using the existing CCD for color measurement. This represents a simple substitution that would reduce hardware costs, complexity, and component count.
    • Expectation of Success: Petitioner argued it would be obvious to use the already-existing image data from a CCD as the input for a color balance feedback loop, as this merely substitutes one data source (a dedicated sensor) for another (the image sensor's output) to perform the same known function.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 19 and 22 are obvious over Kaelin alone (Ground 1); claim 23 is obvious over Mueller, Kaelin, and Hochstein for adding frequency modulation (Ground 4); claims 10 and 21 are obvious over Mueller, Kaelin, Okino, and Hochstein (Ground 5); and claim 40 is obvious over Mueller, Okino, and Hochstein for feedback based on color measurement (Ground 7).

4. Key Claim Construction Positions

  • "LED on-time proportion" (claim 19): Petitioner proposed construing this term as "the total length of time that an LED is in its ‘on’ state, as compared to its ‘off’ state, over a given time duration."
    • Petitioner argued this construction is necessary because while the term often implies pulse width or duty cycle, the ’390 patent specification and dependent claims (specifically claims 20 and 21) indicate that the "on-time proportion" can be controlled by adjusting either the pulse width or the pulse frequency. This broader interpretation was central to Petitioner's ability to rely on prior art that modifies pulse frequency to control brightness.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 7-10, 17-23, and 40 of Patent 6,488,390 as unpatentable under 35 U.S.C. §103.