PTAB

IPR2020-00897

Apple Inc v. Corephotonics Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Optical Lens Assembly
  • Brief Description: The ’277 patent is directed to a compact, five-element optical lens assembly intended for portable devices. The technology aims to provide high-quality imaging within a small total track length (TTL) by claiming specific lens arrangements and optical properties, such as a TTL to effective focal length (EFL) ratio of less than 1.0, an f-number smaller than 2.9, and defined refractive power relationships between the lens elements.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 and 5-8 are obvious over Ogino (Example 4) in view of Bareau

  • Prior Art Relied Upon: Ogino (Patent 9,128,267) and Bareau (a 2006 SPIE proceeding titled "The optics of miniature digital camera modules").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ogino’s Example 4 discloses a five-lens telephoto assembly for portable devices that meets nearly all limitations of the independent claims, including the five-lens structure, the sequence of positive and negative refractive powers for the first few lenses, and a TTL/EFL ratio less than 1.0. The only key feature not explicitly disclosed is a lens assembly f-number smaller than 2.9.
    • Motivation to Combine (for §103 grounds): Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Bareau’s teachings with Ogino's design. Bareau explicitly teaches that typical specifications for cell phone cameras include a low f-number (2.8 or less) to provide sufficient light for small sensors and achieve brighter images. A POSITA would have been motivated to modify Ogino’s existing lens design to achieve this well-known and desirable characteristic to create a competitive product.
    • Expectation of Success (for §103 grounds): Success was argued to be predictable, as modifying an existing lens prescription like Ogino's to achieve a lower f-number is a routine task using standard optical design software. Petitioner provided simulation results showing that Ogino’s Example 4 could be modified to achieve an f-number of 2.8 while maintaining the other claimed structural and performance characteristics.

Ground 2: Claims 1-24 are obvious over Ogino (Example 5) in view of Bareau

  • Prior Art Relied Upon: Ogino (Patent 9,128,267) and Bareau (a 2006 SPIE proceeding).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Ogino’s Example 5, another five-lens telephoto assembly, also discloses the core limitations of the challenged claims. This includes the five-lens arrangement with aspheric surfaces, a TTL/EFL ratio less than 1.0, and specific characteristics for dependent claims, such as the relationship between the focal lengths of the first three lenses (1.2×|f3|>|f2|>1.5×f1) and the distinct Abbe numbers of the fourth and fifth lenses.
    • Motivation to Combine (for §103 grounds): The motivation is largely identical to Ground 1: a POSITA would modify Ogino’s Example 5 to achieve the lower f-number (≤ 2.8) taught by Bareau as desirable for cell phone cameras. Further, Petitioner argued that Ogino itself provides a motivation to modify the design by teaching a desirable range for the air spacing between the third and fourth lenses (L3 and L4) to optimize image quality. A POSITA would have been motivated to explore this disclosed range, leading to a modified design.
    • Expectation of Success (for §103 grounds): Petitioner argued that modifying Ogino's Example 5 was a predictable optimization. It provided two distinct modifications of the Example 5 lens assembly, both achieving an f-number of 2.8, to demonstrate that a POSITA would have arrived at a lens system meeting all limitations of claims 1-24 with a reasonable expectation of success.

4. Key Claim Construction Positions

  • Petitioner stated that no specific claim constructions were necessary for the proceeding beyond plain and ordinary meaning. However, it noted its reliance on constructions adopted by the Board in a related IPR (IPR2018-01140) for two key terms:
    • 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 1-24 of the ’277 patent as unpatentable.