PTAB

IPR2019-00560

LG Electronics Inc v. Cywee Group Ltd

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: 3D Pointing Devices
  • Brief Description: The ’978 patent describes a method for compensating rotations in a 3D pointing device to improve orientation-tracking accuracy. The system uses a nine-axis motion sensor module—comprising rotation sensors, accelerometers, and magnetometers—and applies a mathematical method using quaternions to calculate the device's orientation for controlling a cursor on a 2D display.

3. Grounds for Unpatentability

Ground 1: Obviousness over Zhang and Bachmann - 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 taught a handheld 3D pointing device for a computer control system that used accelerometers and magnetometers to determine its orientation (yaw and pitch). The challenged claims require a nine-axis sensor module (including angular rate sensors) and a method of compensating for rotational errors by comparing measured and predicted magnetism values. Petitioner asserted that Bachmann supplied these missing elements. Bachmann disclosed a complete nine-axis sensor system (three-axis accelerometer, magnetometer, and angular rate sensor) and a quaternion-based attitude estimation filter. This filter calculated a corrected orientation by generating an error vector between actual sensor measurements (including magnetism) and predicted measurements, thereby compensating the output as required by the claims. Dependent claim 12 was met because Bachmann’s orientation output was explicitly a quaternion.
    • Motivation to Combine: A POSITA would combine these references because Zhang expressly suggested that its system was not limited to accelerometers and magnetometers and that "a gyro sensor, can also be used." Bachmann provided a known and commercially available nine-axis "MARG" (Magnetic, Angular Rate, Gravity) sensor system and a superior quaternion-based filter designed to work with it. The motivation was to follow Zhang's suggestion to predictably improve its device's measurement capabilities, such as adding roll detection and enhancing error control, using the known techniques taught by Bachmann.
    • Expectation of Success: A POSITA would have an expectation of success because Bachmann’s sensors were commercially available and its filter algorithms were well-known and implementable on standard microprocessors. The combination was a substitution of known functional blocks (sensors and calculations) for those in Zhang to achieve the expected and promised improvement in orientation tracking.

Ground 2: Obviousness over Liberty and Bachmann - 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: This ground presented a similar argument to Ground 1, substituting Liberty for Zhang as the primary reference. Petitioner contended that Liberty, which was admitted prior art in the ’978 patent, disclosed a 3D handheld pointing device using rotation sensors and accelerometers for tilt compensation. Like Zhang, Liberty's system lacked magnetometers and the specific compensation method recited in the claims. Petitioner argued Bachmann remedied these deficiencies by teaching the required three-axis magnetometer to complete a nine-axis sensor module. Bachmann's quaternion-based filter, which compares measured and predicted sensor data to correct orientation, was argued to meet the claim limitations for compensating rotations and generating a resultant deviation.
    • Motivation to Combine: The motivation was analogous to Ground 1. Liberty expressly taught that a "variety of different sensors could be employed," specifically including "gyroscopes, magnetometers and cameras." A POSITA, seeking to improve the stability and accuracy of Liberty's device, would be motivated by this express suggestion to incorporate the well-known nine-axis MARG sensor system and computationally efficient quaternion filter from Bachmann. This combination would predictably enhance the device's functionality and error handling.
    • Expectation of Success: The petition argued for a high expectation of success, as the integration involved combining known, commercially available sensors with a device that explicitly contemplated their use. Implementing Bachmann's known filtering techniques into Liberty's system was presented as a task within the ordinary skill of a POSITA, promising predictable improvements in performance rather than any unexpected results.

4. Key Claim Construction Positions

  • "spatial reference frame": Petitioner proposed this term be construed as "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 to mapping accelerometer and angular rate sensor outputs from the prior art, which were measured relative to the device's own moving axes.
  • "rotation output": Petitioner proposed this term be construed as the "output of a rotation sensor." This clarified that the term referred directly to the raw data from an angular rate sensor (gyroscope), which was a direct input into the orientation filter taught by Bachmann.

5. Arguments Regarding Discretionary Denial

  • Petitioner noted it was filing the petition concurrently with a Motion for Joinder to an already-instituted proceeding, Google LLC v. Cywee Group Ltd., IPR2018-01257. The petition asserted it was "substantially identical" to the petition in the Google IPR, using the same grounds, prior art, and evidence against the same claims. This was presented as a reason for the Board to institute review and not exercise discretionary denial.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 10 and 12 of the ’978 patent as unpatentable.