PTAB
IPR2020-00192
Samsung Electronics Co Ltd v. Neodron Ltd
Key Events
Petition
Table of Contents
petition Intelligence
1. Case Identification
- Case #: IPR2020-00192
- Patent #: 8,502,547
- Filed: November 27, 2019
- Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
- Patent Owner(s): Neodron Ltd.
- Challenged Claims: 1-17
2. Patent Overview
- Title: Capacitive Sensor
- Brief Description: The ’547 patent relates to a capacitive sensing apparatus, system, and method where a parameter's value, such as light brightness or color, is adjusted based on the duration of a user's touch on a sensing element.
3. Grounds for Unpatentability
Ground 1: Obviousness over Alameh and Puolitaival - Claims 1-17 are obvious over Alameh in view of Puolitaival.
- Prior Art Relied Upon: Alameh (Application # 2005/0219228) and Puolitaival (Application # 2009/0243790).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Alameh taught a user interface with one or more capacitive sensors for adjusting parameters like speaker volume or backlighting level. Critically, Alameh’s processor could determine the "duration of the sensor activation" and "gradually increasing or decreasing" the parameter value based on that duration. Petitioner asserted that Puolitaival supplemented this by explicitly teaching a device where "controlling means" determine the "duration of a touch" to adjust parameters of an illumination source, including "illumination strength, optical band (colour) or contrast."
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because both addressed the same problem of simplifying complex user interfaces by using the same solution of duration-based touch input. A POSITA would have been motivated to integrate Puolitaival's specific teachings on color and brightness control into Alameh's more general user interface framework to predictably enhance its functionality and improve the user experience.
- Expectation of Success: The combination involved applying a known technique (duration-based control of color) to a similar device (an electronic user interface), which would have resulted in a predictable improvement with a high expectation of success.
Ground 2: Obviousness over Alameh and Goederen-Oei - Claims 1-17 are obvious over Alameh in view of Goederen-Oei.
- Prior Art Relied Upon: Alameh (Application # 2005/0219228) and Goederen-Oei (Application # 2008/0259590).
- Core Argument for this Ground:
- Prior Art Mapping: As in Ground 1, Petitioner relied on Alameh for the foundational system of adjusting a parameter based on touch duration. Petitioner argued that Goederen-Oei taught a user interface device, such as a remote controller, for controlling the color, saturation, hue, and brightness of a light source. Goederen-Oei explicitly disclosed that "long pressing" an upper button increases brightness and "long pressing" a lower button decreases it, directly linking touch duration to parameter adjustment.
- Motivation to Combine: A POSITA would combine Alameh and Goederen-Oei because they are in the common field of user interface control and both use touch duration to adjust device parameters. A POSITA would find it obvious to apply Goederen-Oei's specific and well-defined controls for color lighting to Alameh's general interface system to create a more capable and user-friendly device.
- Expectation of Success: Petitioner argued that since both references taught adjusting light brightness via touch duration and disclosed using LEDs, a POSITA would have reasonably expected success in combining their teachings to achieve the claimed invention without any unexpected results.
Ground 3: Obviousness over Grinshpoon and Puolitaival - Claims 1-14 and 16-17 are obvious over Grinshpoon in view of Puolitaival.
- Prior Art Relied Upon: Grinshpoon (Application # 2006/0055679) and Puolitaival (Application # 2009/0243790).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Grinshpoon taught a capacitive touch dimmer circuit where a controller determines if a touch is a "long touch" or a "short touch" to turn a light on/off and adjust its brightness. A continuous "long" touch would cause the dimmer to increase or decrease the light's intensity. Petitioner argued that Puolitaival provided the additional teachings of adjusting color parameters and using LEDs as the light source, which were not explicitly disclosed in Grinshpoon.
- Motivation to Combine: A POSITA would combine the teachings to enhance Grinshpoon's brightness-only dimmer circuit with the color-adjustment capabilities taught by Puolitaival. This would be a simple and logical step to improve the device's functionality and marketability by adding a desirable, known feature.
- Expectation of Success: Applying color control to a device that already controls brightness was a matter of design choice. Furthermore, using LEDs as a light source, as taught by Puolitaival, was a well-known and conventional practice in lighting design, leading to a high expectation of success.
- Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 15 based on the combination of Grinshpoon, Puolitaival, and Goederen-Oei, adding Goederen-Oei for its teachings on wireless communication modules.
4. Key Claim Construction Positions
- Petitioner argued that the term "sensing element," which appears in every independent claim, should be construed consistent with the patent's specification to mean "physical electrical sensing element made of conductive substances."
5. Key Technical Contentions
- Priority Date: Petitioner contended that the ’547 patent was not entitled to its claimed priority date of October 20, 2006. The central inventive concept—adjusting a parameter value based on the duration of a capacitance change—was allegedly first disclosed in a continuation-in-part application filed on December 22, 2008. Therefore, Petitioner argued that this later date is the effective priority date for the purpose of identifying prior art.
6. Relief Requested
- Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-17 of Patent 8,502,547 as unpatentable under 35 U.S.C. §103.
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