PTAB

IPR2019-00719

SZ DJI Technology Co Ltd v. Dareltech LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Handheld Device for Mobile Phone Photography
  • Brief Description: The ’627 patent discloses a handheld device for holding and wirelessly operating a mobile phone's camera. The device comprises a holder for the phone coupled to a handle apparatus that includes controls, a power supply, and wireless communication modules to facilitate remote photography and videography.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rosenhan - Claims 29, 33-36, and 38 are obvious over Rosenhan.

  • Prior Art Relied Upon: Rosenhan (Application # 2013/0005401).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rosenhan teaches an ergonomic smartphone handle mount designed for single-handed control of photography functions. Rosenhan disclosed a mounting structure ("holder") coupled to a grippable portion ("handle apparatus") with control buttons (e.g., zoom, record) and an electronic interface that could be wireless (e.g., Bluetooth) to operate the smartphone's camera. Petitioner asserted that Rosenhan taught every limitation of independent claim 29, with the potential exception of an express disclosure of a "control command" being sent.
    • Motivation to Combine (for §103 grounds): This ground was based on a single reference. Petitioner contended that sending a "control command" is the obvious and inherent result of pressing a button on a remote control that is wirelessly connected to a device to perform a specific function. A POSITA would have understood that Rosenhan's system necessarily operated by sending such commands.
    • Expectation of Success: A POSITA would have an absolute expectation of success that pressing a control button on Rosenhan's handle would generate and transmit a corresponding command to operate the intended camera function.

Ground 2: Obviousness over Rosenhan and Kim - Claims 1, 2, 4-14, 16, 17, 30, 31, and 37 are obvious over Rosenhan in view of Kim.

  • Prior Art Relied Upon: Rosenhan (Application # 2013/0005401) and Kim (WO 2012/096433).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Rosenhan provided the primary device: a handle with integrated controls and wireless communication for operating a smartphone camera. However, Rosenhan's phone mount was designed for a specific phone size. Kim was introduced to teach the missing "spring-loaded holder" limitation, disclosing an adjustable, spring-actuated phone mount with a sliding mechanism capable of securing mobile phones of various sizes and thicknesses.
    • Motivation to Combine: A POSITA would combine Kim's adjustable, spring-loaded holder with Rosenhan's handle and control system to overcome the limitation of Rosenhan's fixed-size mount. Given the rapidly changing form factors of smartphones, creating a versatile accessory compatible with a wide range of devices was a well-known market driver. The combination represented a simple substitution of one known type of phone holder for another to achieve the predictable benefit of universal compatibility.
    • Expectation of Success: A POSITA would have a high expectation of success in integrating Kim's mechanical spring-loaded mount with Rosenhan's electronic handle, as it was a combination of known elements for their intended purposes.

Ground 3: Obviousness over Rosenhan and Lee - Claims 18, 21-25, and 32 are obvious over Rosenhan in view of Lee.

  • Prior Art Relied Upon: Rosenhan (Application # 2013/0005401) and Lee (Korean Application # 10-2012-0040824A).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring both a wireless interface and a Universal Serial Bus (USB) interface. While Rosenhan disclosed that its electronic interface could be either wireless or wired (e.g., USB), it did not explicitly describe an embodiment containing both. Lee was cited for its teaching of a smartphone handle accessory that explicitly included both a wireless (Bluetooth) interface for remote control and a wired physical connector for functions like charging.
    • Motivation to Combine: A POSITA would be motivated to incorporate both wired and wireless interfaces, as taught by Lee, into Rosenhan's design. This combination would enhance the product's utility by allowing it to operate with phones that lack wireless capabilities, enabling use when wireless is disabled (e.g., airplane mode), and permitting simultaneous charging and remote operation. These advantages provided a strong motivation to combine the known interface technologies.
    • Expectation of Success: Adding a standard USB port alongside a Bluetooth module in a battery-powered electronic accessory was a routine and well-understood design choice with a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges against other claims by combining all three references (Rosenhan, Kim, and Lee) to address claims reciting limitations taught by the various combinations.

4. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner contended that the ’627 patent qualifies as an AIA patent, despite its claim to a pre-AIA priority date. The argument asserted that the Chinese Priority Application failed to provide adequate written description support for the "spring-loaded holder" and "one or more springs" limitations recited in numerous challenged claims. Consequently, Petitioner argued that these claims were entitled only to the later, post-AIA filing date of the U.S. application, making the patent subject to post-AIA IPR proceedings.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-38 of Patent 9,503,627 as unpatentable.