PTAB

IPR2020-00475

Samsung Electronics Co Ltd v. Cellect LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Reduced Area Imaging Device
  • Brief Description: The ’052 patent describes a compact imaging device, suitable for medical instruments like endoscopes, that minimizes its profile by arranging components on different planes. The invention places an image sensor on a first plane and video processing circuitry on a separate, parallel second plane in a stacked configuration.

3. Grounds for Unpatentability

Ground 1: Claim 1 is obvious over Wakabayashi in view of Ackland.

  • Prior Art Relied Upon: Wakabayashi (Patent 5,903,706) and Ackland (Patent 5,835,141).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wakabayashi taught the core structural elements of claim 1, including a portable imager apparatus with a housing, an image sensor on a first circuit board (a first plane), and a second, offset circuit board (a second plane) containing processing circuitry. Wakabayashi’s system was designed to be compact. Petitioner contended that Ackland supplied the conventional details of a CMOS-based imaging system that Wakabayashi’s more general “solid-state imager” would have incorporated. Specifically, Ackland disclosed an active pixel imaging system with an array of CMOS pixels, per-pixel amplifiers, and associated timing and control circuitry for generating a pre-video signal, all of which were well-known features for solid-state cameras at the time.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Ackland’s specific CMOS imager teachings with Wakabayashi’s portable device architecture to achieve Wakabayashi’s stated goal of a compact, lightweight imager. Implementing Wakabayashi’s imager using Ackland’s well-known CMOS technology was presented as an obvious design choice to benefit from the known advantages of CMOS sensors, such as smaller size, lower power consumption, and lower cost, which were pertinent to the problem Wakabayashi sought to solve.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, as integrating a known type of image sensor (Ackland) into a portable camera body (Wakabayashi) was a routine and predictable task in the field of camera design.

Ground 2: Claim 1 is obvious over Wakabayashi in view of Ackland and Suzuki.

  • Prior Art Relied Upon: Wakabayashi (Patent 5,903,706), Ackland (Patent 5,835,141), and Suzuki (Patent 5,233,426).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1, adding Suzuki to explicitly teach the dimensional limitation of claim 1 not expressly disclosed in Wakabayashi or Ackland. Petitioner asserted that Suzuki disclosed a compact camera head where a solid-state image pickup chip is mounted on a series of stacked boards. Suzuki taught that when an 8.5 mm chip is used, the outer diameter of the camera head is about 10 mm. This explicitly disclosed an image sensor assembly with a largest dimension between the claimed 2 and 12 millimeters.
    • Motivation to Combine: A POSITA, seeking to further Wakabayashi's goal of miniaturization, would look to known compact camera designs like Suzuki. A POSITA would combine Suzuki’s teachings on component sizing and stacked arrangement to make the Wakabayashi/Ackland device smaller and more compact, which was a primary objective in the field.
    • Expectation of Success: The combination was argued to be predictable, as it involved applying a known miniaturization technique and component sizing (from Suzuki) to a known camera architecture (Wakabayashi/Ackland) to achieve the expected result of a smaller device.

Ground 3: Claims 3 and 7 are obvious over Wakabayashi in view of Ricquier and Dierickx.

  • Prior Art Relied Upon: Wakabayashi (Patent 5,903,706), Ricquier (a 1994 conference paper), and Dierickx (Application # 2001/0010551).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Wakabayashi again provided the foundational portable imager with stacked circuit boards. Ricquier, a paper on CMOS imagers, was cited to supply the teaching of a CMOS pixel array on a planar substrate with off-chip timing and control circuitry that generates a pre-video signal. Dierickx was introduced to teach that each pixel in a CMOS array could include an amplifier to improve image quality and reduce noise, a feature not specified in Ricquier. Furthermore, Dierickx disclosed an image sensor with dimensions of 6.3x5.7 mm (satisfying the 2-12 mm limitation) and a generally square shape, satisfying additional limitations in claim 7.
    • Motivation to Combine: A POSITA would combine Ricquier's specific CMOS array architecture into Wakabayashi’s device for its known advantages, such as selective addressability and multiple resolutions. A POSITA would further incorporate Dierickx’s teaching of active pixels with per-pixel amplifiers to improve the performance of the Ricquier-based imager, as improving image quality and reducing noise were well-known design goals. The dimensional and shape teachings from Dierickx would be adopted to meet the overarching goal of miniaturization.
    • Expectation of Success: A POSITA would expect this combination to work predictably, as it involved integrating known, compatible components (CMOS arrays, active pixels, specific-sized sensors) to improve the functionality and reduce the size of a known camera system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) was not warranted. It asserted that the co-pending district court litigation was in its early stages, with infringement contentions having been served only a few months prior to the petition filing, and therefore the Fintiv factors weighed against denial.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 3, and 7 of the ’052 patent as unpatentable under 35 U.S.C. §103.