PTAB

IPR2019-00534

Samsung Electronics Co Ltd v. Cywee Group Ltd

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1. Case Identification

2. Patent Overview

  • Title: Method for Compensating Rotations of a 3D Pointing Device
  • Brief Description: The ’978 patent discloses methods for improving the accuracy of orientation tracking for 3D pointing devices. The system uses data from a nine-axis sensor module (comprising rotation sensors, accelerometers, and magnetometers) and employs quaternion-based mathematics to compensate for sensor errors and calculate the device's orientation relative to a global reference frame.

3. Grounds for Unpatentability

Ground 1: Claims 10 and 12 are obvious over Zhang in view of Bachmann.

  • Prior Art Relied Upon: Zhang (Application # 2004/0095317) and Bachmann (Patent 7,089,148).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zhang teaches a handheld 3D pointing device that uses accelerometers and magnetometers to determine orientation for controlling a cursor and expressly suggests that other sensors, such as a "gyro sensor," could be added. Bachmann was argued to supply the remaining limitations by teaching a complete nine-axis sensor system (a "MARG" sensor including three-axis accelerometers, magnetometers, and angular rate sensors) and an attitude estimation filter. Bachmann's filter calculates orientation using quaternions and compensates for errors by comparing measured sensor data (for magnetism and acceleration) to predicted data, directly mapping to the method steps of challenged claim 10.
    • Motivation to Combine: A POSITA would combine Bachmann's nine-axis sensor system and filter with Zhang's device because Zhang explicitly suggests adding gyroscopes to improve functionality. Bachmann's system represented a known, commercially available solution for improving orientation tracking accuracy and enabling the detection of more complex movements (e.g., roll). The combination was presented as a predictable integration of known technologies to achieve an expected improvement.
    • Expectation of Success: Petitioner asserted a high expectation of success because the sensor components and quaternion-based filter techniques described in Bachmann were well-known in the art and designed to work together. Integrating these known functional blocks into Zhang's similar system would have required only ordinary skill.

Ground 2: Claims 10 and 12 are obvious over Liberty in view of Bachmann.

  • Prior Art Relied Upon: Liberty (Patent 7,158,118) and Bachmann (Patent 7,089,148).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Liberty, which is admitted prior art in the ’978 patent, discloses a 3D pointing device using accelerometers and rotation sensors for tilt compensation. Crucially, Liberty expressly teaches that its system can be improved by employing additional sensors, including magnetometers and gyroscopes. As in the first ground, Bachmann provides the specific teachings of a nine-axis MARG sensor system and a quaternion-based filter that uses predicted vs. measured values to correct the orientation output. This combination allegedly meets all limitations of claim 10.
    • Motivation to Combine: The motivation was argued to be explicit in Liberty, which suggests using the very types of sensors taught by Bachmann to enhance performance. A POSITA would have recognized Bachmann's integrated nine-axis system and filter as an off-the-shelf solution to implement Liberty’s suggestion. This combination represents the use of a known technique (Bachmann's filter) to improve a similar device (Liberty's pointer) in a predictable way, consistent with the principles of KSR.
    • Expectation of Success: Similar to the first ground, the combination involved integrating a known, commercially available sensor suite and its associated processing methods into a device that was expressly designed to be compatible with such an upgrade. A POSITA would have reasonably expected the combined system to function as intended.

4. Key Claim Construction Positions

  • "spatial reference frame": Petitioner argued this term should be construed to mean "a reference frame associated with the 3D pointing device, which always has its origin at the same point in the device and in which the axes are always fixed with respect to the device." This construction was critical for mapping the sensor outputs from the prior art, which are measured relative to the device's body, to the claim language.
  • "rotation output": Petitioner proposed that this term means the "output of a rotation sensor." This construction anchors the term to the raw data from a specific piece of hardware (e.g., a gyroscope), which Petitioner then identified in the prior art references.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate because the petition was filed concurrently with a Motion for Joinder with an already-instituted IPR proceeding (IPR2018-01257, Google LLC v. Cywee Group Ltd.). Petitioner contended that under the Board's rules at the time, the one-year statutory time bar for filing a petition did not apply when accompanied by a request for joinder.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 10 and 12 of Patent 8,552,978 as unpatentable under 35 U.S.C. §103.