PTAB

IPR2020-00334

Samsung Electronics Co Ltd v. Neodron Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Touch Sensor with Aligned Electrodes
  • Brief Description: The ’106 patent relates to capacitive touch sensors integrated with displays. The core inventive concept involves arranging the touch sensor’s crisscrossing electrodes so they are aligned with the non-emissive gaps between the display’s pixels, thereby reducing their visibility and improving optical performance.

3. Grounds for Unpatentability

Ground 1: Obviousness over Masanori, Alone or in Combination with Geaghan - Claims 1-4, 7-9, 11-13, 15-19, and 21-22 are obvious over Masanori, either alone or in view of Geaghan.

  • Prior Art Relied Upon: Masanori (Japanese Patent Publication No. 2009-259063) and Geaghan (Application # 2009/0219258).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Masanori discloses all key limitations of the independent claims. Masanori teaches a capacitive touch panel for a display comprising a two-dimensional pixel array and first and second pluralities of orthogonal electrodes. Crucially, Masanori discloses positioning these electrodes on the "black matrix" that fills the gaps between pixels to prevent them from crossing over and obstructing the light-emitting pixel areas. Petitioner asserted that this arrangement inherently means the vertices formed by the crisscrossing electrodes are also aligned within these gaps. Masanori further teaches separating the electrode layers by dielectric substrates, which provides the claimed capacitive coupling at the vertices. For dependent claims requiring "fine lines of metal electrodes," Petitioner argued this is either inherently taught by Masanori's "ultrafine" electrodes or rendered obvious by Geaghan, which explicitly discloses forming electrode meshes from fine metallic traces with widths between 0.5 and 10 micrometers.
    • Motivation to Combine: A POSITA would combine Masanori and Geaghan because both references are in the same field of capacitive touch sensors and address the common objective of reducing electrode visibility to improve the optical quality of the integrated display. Combining Geaghan’s well-known fine-line metal electrodes with Masanori’s sensor architecture represented a predictable design choice to achieve this shared goal.
    • Expectation of Success: A POSITA would have had a high expectation of success in applying Geaghan's known fine-line manufacturing techniques to Masanori's sensor design, as it involved the simple substitution of one known type of electrode for another to yield predictable improvements in transparency.

Ground 2: Obviousness over Polishchuk, Alone or in Combination with Geaghan - Claims 1-4, 7-9, 11-13, 15-19, and 21-22 are obvious over Polishchuk, either alone or in view of Geaghan.

  • Prior Art Relied Upon: Polishchuk (Application # 2012/0044187) and Geaghan (Application # 2009/0219258).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Polishchuk, like Masanori, discloses the core features of the challenged claims. Polishchuk describes a capacitive touch screen with horizontal and vertical electrodes that can be patterned over a display device. It explicitly teaches that "each of the electrodes... can be aligned with, within, or positioned over a gap or mask between pixels of the display device" to reduce their visibility. Petitioner argued that this alignment of both electrode sets within the inter-pixel gaps necessarily means their crisscrossing vertices are also aligned with the gaps, meeting a key limitation of the independent claims. Polishchuk also shows the electrodes are insulated by a dielectric separator where they cross, creating the claimed capacitive coupling. As in Ground 1, Geaghan was cited as a secondary reference to explicitly teach forming the electrode grid as a mesh of fine metal lines, if Polishchuk’s disclosure of electrodes with a width of 10 micrometers or less were deemed insufficient.
    • Motivation to Combine: A POSITA would combine Polishchuk and Geaghan to leverage the known benefits of both technologies. Both references concern integrating transparent touch sensors with displays and aim to minimize the visual impact of the sensor's conductive traces. Using Geaghan’s established method for creating fine-line electrode meshes was an obvious way to further enhance the transparency of the sensor described in Polishchuk.
    • Expectation of Success: There was a reasonable expectation of success, as combining the teachings merely involved applying a known electrode manufacturing technique (Geaghan) to a known sensor layout (Polishchuk) to achieve the predictable result of improved optical performance.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claim 10 (requiring flexibility) based on combinations of Masanori with Gandhi (Application # 2009/0085894) and Polishchuk with Gandhi, arguing Gandhi explicitly taught integrating such touch sensors with flexible displays.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. §325(d), even though Polishchuk was considered during prosecution. Petitioner contended that the Examiner relied on Polishchuk only as a secondary reference to teach a specific gap dimension for dependent claim 22. In contrast, the petition utilized Polishchuk as the primary reference in a new theory of unpatentability against all independent claims and numerous other dependent claims, an argument the Examiner never considered. This substantive difference, along with the introduction of non-cumulative prior art like Masanori and Geaghan, warranted a full review on the merits.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 7-13, 15-19, and 21-22 of the ’106 patent as unpatentable under 35 U.S.C. §103.