PTAB

IPR2020-00877

Apple Inc v. Corephotonics Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Device with Integrated Camera
  • Brief Description: The ’840 patent is directed to a mobile electronic device with an integrated dual-camera system. The system includes a Wide camera unit and a Telephoto camera unit, each with distinct optical paths and lens properties, particularly focusing on the ratio of Total Track Length (TTL) to Effective Focal Length (EFL) for each unit.

3. Grounds for Unpatentability

Ground 1: Obviousness over Parulski, Huang, and Tang - Claims 1, 2, 5, 7, 11-13, 15, 16, 18, 20-21 are obvious over Parulski in view of Huang and Tang.

  • Prior Art Relied Upon: Parulski (Patent 7,859,588), Huang (Patent 9,726,858), and Tang (Patent 8,363,337).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Parulski taught the foundational concept of a mobile phone with an integrated dual-camera system comprising both wide-angle and telephoto lenses. However, Parulski provided a general framework without specific lens prescription data. To implement Parulski’s system, a person of ordinary skill in the art (POSITA) would have looked to known lens designs suitable for mobile applications. Huang disclosed a detailed miniature telephoto lens unit with a TTL/EFL ratio smaller than 1, meeting a key limitation of the challenged claims. Similarly, Tang disclosed a compact wide-angle lens unit with a TTL/EFL ratio larger than 1, meeting the corresponding claim limitation. Petitioner asserted that Huang’s telephoto lens also met the detailed dependent claim limitations regarding lens element groupings, materials, Abbe numbers, and optical power characteristics.
    • Motivation to Combine: A POSITA seeking to build the dual-camera system in Parulski would be motivated to use specific, high-performance lens designs like those in Huang and Tang. Both Huang and Tang were explicitly designed for compact mobile devices, making them suitable replacements for the generic lenses in Parulski. Parulski’s stated goal of maintaining a small device thickness would further motivate the use of Huang’s and Tang’s compact lens designs. The combination was presented as a predictable substitution of known components to achieve a well-known result.
    • Expectation of Success: Petitioner contended a POSITA would have a reasonable expectation of success because combining these modular, purpose-built lens units into Parulski’s system involved applying known design principles. The compatibility of the components for use in mobile devices ensured the combination would function as intended.

Ground 2: Obviousness over Parulski, Huang, Tang, and May - Claims 3 and 4 are obvious over Parulski in view of Huang and Tang, further in view of May.

  • Prior Art Relied Upon: Parulski (Patent 7,859,588), Huang (Patent 9,726,858), Tang (Patent 8,363,337), and May (Patent 7,561,191).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the primary combination of Parulski, Huang, and Tang to establish the complete dual-lens camera system. May was added to address the limitations of claims 3 and 4, which require the Wide and Telephoto camera units to be mounted on separate printed circuit boards (PCBs), potentially in different parallel planes. May explicitly taught various multi-lens camera layouts for mobile phones where camera subassemblies were mounted on separate substrates to enhance design flexibility and optical performance.
    • Motivation to Combine: A POSITA would combine May’s modular mounting approach with the camera system from the primary combination to gain design flexibility. Since the telephoto lens (from Huang) and wide-angle lens (from Tang) had different track lengths, mounting them on separate, parallel PCBs as taught by May was a logical and advantageous design choice. The fact that Kenneth Parulski was an inventor on both the Parulski and May patents was argued to strengthen the motivation to combine their teachings.
    • Expectation of Success: Success would be expected, as mounting camera modules on separate PCBs was a known technique for managing different component depths and optimizing layout in compact electronic devices.

Ground 3: Obviousness over Parulski, Huang, Tang, and Li II - Claim 6 is obvious over Parulski in view of Huang and Tang, further in view of Li II.

  • Prior Art Relied Upon: Parulski (Patent 7,859,588), Huang (Patent 9,726,858), Tang (Patent 8,363,337), and Li II (Patent 8,189,100).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground uses the primary combination to supply the specific dual-lens camera system and adds Li II to teach the limitation of claim 6, which requires the camera units to be spaced "a distance d of about 1 mm." Li II disclosed a mobile device with dual camera sensors whose relative positions could be adjusted. Li II explicitly stated that the distance between the sensors could range from several centimeters to a distance that "approaches zero," a range that inherently includes approximately 1 mm.
    • Motivation to Combine: Li II taught that adjusting the spacing between camera sensors provided benefits such as increased image dynamic range. A POSITA would be motivated to incorporate Li II’s teaching of close and adjustable spacing into the Parulski/Huang/Tang camera system to achieve these known benefits and optimize performance within the physical constraints of a mobile phone.
    • Expectation of Success: The combination was presented as a predictable application of a known technique (adjusting inter-lens spacing) to a known system for an expected improvement in image quality.

4. Key Claim Construction Positions

  • "Total Track Length (TTL)": Petitioner argued this term should be construed as "the length of the optical axis spacing between the object-side surface of the first lens element and the image plane." This construction was asserted to be consistent with the specification and definitions known in the art, and it was critical for calculating the TTL/EFL ratio of the prior art lenses to show they met the claim limitations.
  • "Effective Focal Length (EFL)": Petitioner argued this term should be construed as "the focal length of a lens assembly." This well-known optical term was likewise essential for calculating the TTL/EFL ratio that formed a central element of the obviousness analysis for claim 1.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7, 11-13, 15, 16, 18, 20, and 21 of Patent 10,288,840 as unpatentable.