PTAB

IPR2020-00477

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 ’896 patent discloses a compact imaging device, intended for applications like medical endoscopes, that minimizes its physical profile by arranging circuitry in a stacked configuration. The design separates an image sensor, located on a first plane, from its video processing circuitry, which is located on a second, parallel circuit board.

3. Grounds for Unpatentability

Ground 1: Obviousness over Wakabayashi and Ackland - Claims 1, 5, and 21 are 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 the combination of Wakabayashi and Ackland teaches every limitation of the challenged claims. Wakabayashi was asserted to disclose the core structural arrangement of the claimed invention: a portable imager apparatus with a compact video camera unit. This unit includes an image sensor on a first circuit board and a separate, second circuit board for signal processing, arranged in a parallel, offset configuration within a housing. Petitioner contended that Wakabayashi’s figures and description inherently disclose that the second circuit board has a larger dimension than the image sensor—the key limitation added during prosecution to overcome the Examiner’s rejections. Ackland was presented as supplying the specific, well-known details of the image sensor technology itself, which Wakabayashi describes more generally. Ackland teaches an imaging system using a CMOS active pixel array where each pixel includes an amplifier, along with the necessary timing and control circuitry to read out a pre-video signal.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to implement the specific CMOS sensor technology taught by Ackland within the portable device architecture of Wakabayashi. The primary motivation was to achieve the shared, well-known industry goals of miniaturization and cost reduction. Ackland’s CMOS active pixel sensor technology was known to be smaller, consume less power, and be cheaper to fabricate than other sensor types. A POSITA would therefore combine Ackland’s superior sensor with Wakabayashi’s compact, stacked-board layout to predictably create a smaller, more efficient, and lower-cost imaging device. Petitioner also argued it would have been an obvious design choice to place the processing circuitry on Wakabayashi's larger second circuit board to further reduce the size of the camera head.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved applying a well-understood and advantageous sensor technology (Ackland) into a known mechanical and electrical framework for a portable camera (Wakabayashi). The ’896 patent itself acknowledges that the individual components were well-known in the art, making their integration a matter of predictable engineering rather than inventive insight.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) or §325(d) would be inappropriate. It was contended that the grounds presented were not cumulative to art considered during prosecution, as neither Wakabayashi nor Ackland was cited or applied by the Examiner. Petitioner also asserted that the co-pending district court litigation was in its early stages, with infringement contentions having been served only a few months prior, and therefore factors related to parallel proceedings did not weigh in favor of denial.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1, 5, and 21 of the ’896 patent as unpatentable under 35 U.S.C. §103.