PTAB

IPR2020-00896

Apple Inc v. Corephotonics Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Five-Element Telephoto Lens Assembly
  • Brief Description: The ’647 patent is directed to a compact, high-performance optical lens assembly for portable electronics. The assembly includes five lens elements and provides a telephoto effect, characterized by a total track length to effective focal length ratio (TTL/EFL) of less than 1.0, to achieve high-quality imaging in a small form factor.

3. Grounds for Unpatentability

Ground 1: Obviousness over Iwasaki - Claims 1-3 and 5 are obvious over Iwasaki.

  • Prior Art Relied Upon: Iwasaki (Patent 9,678,310).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Iwasaki, which discloses a fixed-focus imaging lens for portable devices, renders the challenged claims obvious. Specifically, Petitioner asserted that Example 4 of Iwasaki teaches a five-lens telephoto assembly that meets every limitation of independent claim 1. Iwasaki’s Example 4 allegedly discloses the required sequence of five lens elements with positive and negative refractive powers, a TTL of 3.89 mm, an EFL of 4.00 mm, and an F-number (F#) of 2.8. These parameters satisfy the claimed TTL/EFL ratio of <1.0 (0.9725), TTL of ≤6.5 mm, and F# of <2.9. Furthermore, Iwasaki’s inclusion of a cover glass element was argued to teach the claimed "window."
    • Motivation to Combine: Not applicable as this is a single-reference ground.

Ground 2: Obviousness over Ogino and Chen II - Claims 1 and 4 are obvious over the combination of Ogino and Chen II.

  • Prior Art Relied Upon: Ogino (Patent 9,128,267) and Chen II (Patent 8,233,224).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Ogino’s Example 5 discloses a five-lens telephoto system that is structurally similar to the claimed invention. However, Ogino’s biconcave second lens (L2) causes significant vignetting (light blockage) and reduces relative illumination at the edge of the image field to below 50%. Chen II was introduced as a reference that teaches a similar five-lens system but advantageously uses a meniscus-shaped L2 to reduce vignetting and improve illumination. Petitioner argued that a person of ordinary skill in the art (POSITA) would modify Ogino’s lens assembly by substituting its biconcave L2 with the meniscus-shaped L2 taught by Chen II. This predictable modification would result in a lens assembly that meets all limitations of claim 1, including the meniscus shape with a convex object-side surface for the second lens.
    • Motivation to Combine: A POSITA would combine Ogino with Chen II to solve a known optical performance issue in Ogino’s design. The motivation was to improve Ogino's lens by reducing vignetting and increasing relative illumination, thereby producing brighter, higher-quality images. This modification addresses a well-understood design trade-off using a known solution from a similar system.
    • Expectation of Success: Petitioner argued that a POSITA would have a high expectation of success. The proposed modification involves substituting one known type of lens element for another to achieve a predictable improvement in optical performance, which constitutes a routine design adjustment readily modeled and verified using standard optical design software.

Ground 3: Obviousness over Ogino, Chen II, and Bareau - Claims 2, 3, 5, and 8-11 are obvious over the combination of Ogino, Chen II, and Bareau.

  • Prior Art Relied Upon: Ogino, Chen II, and Bareau (a 2006 SPIE publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Ogino/Chen II combination to address claims requiring a lower F-number (e.g., F# < 2.9) and other specific dimensional relationships. Bareau was presented as evidence that an F# of 2.8 or less was a "typical lens specification" for cell phone cameras to ensure sufficient light capture for small pixel sensors. Petitioner argued that a POSITA would further optimize the Ogino/Chen II design to meet this well-known industry standard.
    • Motivation to Combine: The primary motivation was to create a commercially competitive lens design. A POSITA would apply Bareau's teaching regarding a desirable F-number to the base Ogino/Chen II lens system. This would involve known design techniques, such as increasing the diameter of the lens elements, to predictably achieve an F# of 2.8 while maintaining the compact telephoto structure.
    • Expectation of Success: Modifying a lens design to achieve a lower F-number was portrayed as a standard, predictable task for a POSITA.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including: (1) adding Kingslake to the Ogino/Chen II/Bareau combination to further evidence the motivation for faster lenses; (2) combining Hsieh and Beich to argue claim 7 is obvious based on manufacturability rules of thumb for plastic optics; and (3) combining Chen, Iwasaki, and Beich to argue claim 12 is obvious based on motivations to use a thinner IR filter and adhere to manufacturing best practices.

4. Key Claim Construction Positions

  • Petitioner stated that no specific constructions were necessary beyond those previously adopted by the Board in a related case (IPR2018-01140) for the same patent family. The key relied-upon constructions were:
    • Effective Focal Length (EFL): "the focal length of a lens assembly."
    • Total Track Length (TTL): "the length of the optical axis spacing between the object-side surface of the first lens element and one of: an electronic sensor, a film sensor, and an image plane corresponding to either the electronic sensor or a film sensor."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of the ’647 patent as unpatentable.