PTAB

IPR2020-00234

Samsung Electronics Co Ltd v. Neodron Ltd

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Capacitive Touch Panel and Driving Method Thereof
  • Brief Description: The ’898 patent discloses a capacitive touch sensor system and method for driving its electrode array. The core technique involves simultaneously driving different sets of multiple adjacent drive lines in a sequential, overlapping manner (e.g., driving lines 1 and 2, then lines 2 and 3, then lines 3 and 4) to detect a touch event.

3. Grounds for Unpatentability

Ground 1: Claims 1-24 are obvious over Hsieh in view of Hotelling-453

  • Prior Art Relied Upon: Hsieh (Patent 8,451,250) and Hotelling-453 (Application # 2008/0006453).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Hsieh discloses the core inventive concept of the ’898 patent: a capacitive touch panel that "sequentially" drives "pairs of driving electrodes" one by one. Specifically, Hsieh teaches driving adjacent electrodes X1 and X2 at a first time, then X2 and X3 at a second time, and so on. Petitioner asserted this directly maps to the limitations in independent claims 1, 9, and 17 requiring driving a first and second adjacent line, followed by driving the second and a third adjacent line. Hotelling-453 was argued to supply the limitation of "one or more computer-readable non-transitory storage media" embodying logic, which Hsieh's disclosure of a generic "controller" lacked specific detail on.
    • Motivation to Combine: A POSITA would combine these references to implement the controller in Hsieh's touch panel system. Petitioner contended that while Hsieh taught the driving scheme, it provided no detail on the controller's implementation. Hotelling-453, from the same field, taught a conventional controller using a processor executing instructions from memory, providing a known solution to complete Hsieh's system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because using software-controlled processors with memory to manage touch sensor operations, as taught by Hotelling-453, was a well-known and predictable implementation choice at the time.

Ground 2: Claims 1-24 are obvious over Lee

  • Prior Art Relied Upon: Lee (Application # 2011/0109577).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Lee, as a single reference, discloses all limitations of the challenged claims. Lee teaches an apparatus for detecting a touch by applying a drive signal to a "set of at least two" drive lines (columns or rows) and "shifting [the] set" of drive lines "one by one on the touch panel" from one time period to the next. For example, Lee explicitly describes driving the "leftmost three columns of sensors" at a first time, "three central columns" at a second time, and the "rightmost three columns" at a third time. Petitioner asserted this method of driving overlapping sets of adjacent lines renders the claims obvious without needing a secondary reference.
    • Motivation to Combine (for §103 grounds): Not applicable as this is asserted as a single-reference obviousness ground. Lee's own disclosure was argued to contain all necessary elements and the motivation to arrange them as claimed.
    • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

Ground 3: Claims 1-2, 4-5, 7-10, 12-13, 15-18, 20-21, and 23-24 are obvious over Lin in view of Hotelling-453

  • Prior Art Relied Upon: Lin (Application # 2011/0210930) and Hotelling-453 (Application # 2008/0006453).
  • Core Argument for this Ground:
    • Prior Art Mapping: The argument mirrors that of Ground 1. Petitioner asserted that Lin discloses driving "successive pairs of adjacent drive lines" one pair at a time and shifting one drive line at a time (e.g., driving X0 and X1, then X1 and X2). This was argued to meet the core claim limitations regarding the sequential driving of overlapping, adjacent drive lines. As with Hsieh, Lin's disclosure of a "driving module" and "sensing unit" lacked specific implementation details. Hotelling-453 was again relied upon to teach the use of a processor-based controller with non-transitory storage media to perform these functions.
    • Motivation to Combine: A POSITA would combine Lin with Hotelling-453 for the same reason as in Ground 1: to provide a well-known, detailed implementation for the generic controller functions described in Lin. The combination solves the problem of how to practically build the controller for Lin's system using established technology.
    • Expectation of Success: Success was expected because implementing controllers for touch panels using processors and memory, as shown in Hotelling-453, was a standard and predictable approach in the art.
  • Additional Grounds: Petitioner asserted that claims 8, 16, and 24 (requiring a set of four electrical pulses) are obvious over Lee in view of Hotelling-167 (Application # 2008/0158167). The argument was that Lee teaches using a generic "periodic pulse," and Hotelling-167 explicitly teaches using a set of four electrical pulses, providing a specific and obvious implementation for Lee's system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. The core argument was that the primary prior art references central to its petition—Hsieh, Lee, and Lin—are materially different from the art considered during prosecution and were never before the Examiner. Petitioner contended these references are not cumulative to the cited art (e.g., Hotelling-167) because they explicitly teach the key limitation of driving different sets of adjacent drive lines at the same time, the very feature added to the claims to overcome prior art rejections during prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of the ’898 patent as unpatentable under 35 U.S.C. §103.