PTAB

IPR2019-01117

NEC Display Solutions Of America Inc v. Ultravision TechnoliGes LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Modular Display Panel
  • Brief Description: The ’782 patent discloses a modular LED display panel designed for outdoor use. The invention features a sealed, waterproof shell containing a printed circuit board (PCB) with LEDs on one side and a driver circuit and power supply unit on the other, along with protective structures like louvers or potting material.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-6, 9-12, 16, 22-25, and 28 are obvious over Tokimoto in view of Kim.

  • Prior Art Relied Upon: Tokimoto (Japanese Application # P2001-337626A) and Kim (Korean Application # 2002-0069818).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tokimoto discloses a thin, panel-type modular LED display that is "virtually waterproof" and "virtually airtight." Tokimoto’s module includes a plastic case (shell) housing a PCB with LEDs, a power input, driver circuits, and a protective front cover with louvers (eaves). However, Tokimoto places its driver circuits on the same side as the LEDs. Kim teaches an ultra-thin, hermetically sealed LED module for outdoor use that improves upon the prior art by locating operating elements (e.g., driver circuits) and a small-capacity power supply on the rear of the PCB, behind a heat sink. This configuration enhances heat dissipation and allows for a thinner panel. Petitioner contended that combining these references renders all limitations of the independent claims obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Tokimoto and Kim because both address the same field of thin, waterproof, modular LED displays. A POSITA would have been motivated to modify Tokimoto’s design by incorporating Kim’s teachings for rear-mounted driver circuits and a power supply. This combination would achieve the predictable benefits of improved thermal management and a thinner panel profile, consistent with the objectives of both references.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involves placing known components (Kim’s rear-mounted drivers and power supply) in a well-understood configuration on the back of a standard PCB within a modular display (Tokimoto), which would not require any redesign or undue experimentation.

Ground 2: Claims 1, 3-6, 9-12, and 16 are obvious over Tokimoto and Kim, in further view of Li.

  • Prior Art Relied Upon: Tokimoto, Kim, and Li (Chinese Application # CN 102930785 A).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground reinforces the argument for locating the driver circuit on the rear of the PCB. Petitioner asserted that to the extent the combination of Tokimoto and Kim is deemed insufficient, Li explicitly teaches an LED display module where the "LED light-emitting component 14 and driver circuit 15 are respectively disposed on opposite sides of the PCB board 13."
    • Motivation to Combine: A POSITA would combine Li with Tokimoto and Kim to gain the explicit benefits taught by Li: enhanced cooling and the ability to achieve a tighter pixel pitch for better image quality. Li’s unambiguous disclosure provides a clear, well-understood solution to a known problem in the field.

Ground 3: Claims 10 and 11 are obvious over Tokimoto and Kim, in further view of Bessho.

  • Prior Art Relied Upon: Tokimoto, Kim, Li, and Bessho (Japanese Application # P2003-92195A).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses the power supply limitations in claims 10 (AC-to-DC converter) and 11 (DC-to-DC down converter). Petitioner argued that while Tokimoto discloses a DC/DC converter, Bessho explicitly teaches an LED display system that uses an AC-DC conversion device to convert commercially available AC power to a higher DC voltage, which is then supplied to multiple modules, each having its own DC-DC down converter.
    • Motivation to Combine: A POSITA would incorporate Bessho’s teachings to improve power grid efficiency, reduce heat, and simplify wiring, which are known benefits of a high-voltage, low-current distribution system. Combining Bessho’s power architecture with the panel of Tokimoto/Kim/Li was presented as a straightforward application of known electrical engineering principles to improve the overall system.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 13 based on Tokimoto, Kim, and Li in further view of Yang (Chinese Utility Model # CN 2834111 Y). Yang was cited for its teaching of housing the power supply in a "metal shielding box" to solve the known problem of radio frequency interference, thereby rendering the "Faraday cage" limitation of claim 13 obvious.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate despite a previously filed petition (IPR2019-00881) challenging the same patent. Petitioner asserted that it is a different entity from the petitioners in the earlier case, that this petition relies on different primary prior art references (Tokimoto and Kim), and that since no institution decision had been issued in the prior case, there was no risk of unfair reliance on a "roadmap" of the Patent Owner’s arguments or waste of Board resources.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1, 3-6, 9-13, 16, 22-25, and 28 of the ’782 patent as unpatentable.