PTAB

IPR2020-01173

Samsung Electronics Co Ltd v. Ultravision Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Modular LED Display Panels
  • Brief Description: The ’294 patent relates to modular light-emitting diode (LED) display panels designed for assembly into larger, multi-panel displays. The patent describes panels with integrated waterproofing features, allowing them to be used outdoors without a separate protective enclosure.

3. Grounds for Unpatentability

Ground 1: Anticipation over Guoshi - Claims 1, 2, 9, 13, and 20 are anticipated by Guoshi.

  • Prior Art Relied Upon: Guoshi (Chinese Application # CN103280164A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Guoshi, which published before the ’294 patent’s priority date, discloses every element of the challenged independent claims. Guoshi teaches a modular LED display panel with a plastic casing containing a recess, a printed circuit board (PCB) disposed in the recess, and a plurality of LEDs arranged in a rectangular array of over fifty pixels on the front of the PCB. Petitioner asserted Guoshi also discloses a framework of louvers (termed "brims") over the PCB, a control circuit and power module attached to the PCB, and comprehensive waterproofing. The front side is sealed with a silicone compound (achieving >IP65 rating), and the plastic casing is sealed with waterproof covers (achieving >IP64 rating), rendering the entire module suitable for outdoor use without an external enclosure.
    • Key Aspects: Petitioner contended that Guoshi’s disclosure is a blueprint for the invention claimed in the ’294 patent, meeting every limitation of the independent claims and key dependent claims, including the use of a sealing compound (claim 2) and having LEDs protrude from the sealant (claim 9).

Ground 2: Obviousness over Guoshi, Kim, and Panagotacos - Claims 7, 18, 20, 22-24, and 26-28 are obvious over Guoshi in view of Kim and Panagotacos.

  • Prior Art Relied Upon: Guoshi (Chinese Application # CN103280164A), Kim (Korean Application # KR 2002-0069818), and Panagotacos (WO 02/23956).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Guoshi teaches the foundational waterproof, modular LED panel. The remaining challenged claims add specific power supply configurations and enhanced waterproofing. Kim teaches modifying a similar LED module to use a completely external power supply, while Panagotacos discloses the conventional components of such a power supply. Specifically, claims 7 and 18 require an AC/DC converter. Petitioner asserted a POSITA would implement the external power supply taught by Kim using the standard AC/DC converter detailed in Panagotacos, as large outdoor displays are powered by AC mains. Claim 22 requires the power supply to be mounted on the outer surface of the panel, which is the explicit teaching of Kim. Claims 24 and 26-28 require a higher degree of waterproofing (submersible up to one meter); Petitioner argued that moving the power supply external per Kim would eliminate holes in the casing, predictably enhancing Guoshi’s already high IP rating to this level.
    • Motivation to Combine: A POSITA would combine Guoshi and Kim to gain known benefits, including improved sealing by eliminating holes for internal power components, reducing panel thickness and weight, and simplifying repair and replacement of the power supply. A POSITA would have looked to a reference like Panagotacos to implement the details of a standard, compact, and efficient power supply for the combined system.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination involves applying a known improvement (Kim's external power supply) to a similar device (Guoshi's panel) and implementing it with well-understood, off-the-shelf components (disclosed by Panagotacos) to achieve predictable results.

Ground 3: Obviousness over Guoshi, Kim, Panagotacos, and Nicholson - Claim 30 is obvious over the combination of Guoshi, Kim, and Panagotacos in view of Nicholson.

  • Prior Art Relied Upon: Guoshi (Chinese Application # CN103280164A), Kim (Korean Application # KR 2002-0069818), Panagotacos (WO 02/23956), and Nicholson (Patent 6,175,342).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted the combination of Guoshi, Kim, and Panagotacos establishes a modular display panel with an external power supply, as argued in Ground 2. Claim 30 adds the limitation of a "receiver card configured to receive external data...the receiver card comprising a unique network address." Petitioner argued this describes the necessary control circuitry for a multi-panel display to function. Nicholson was cited as teaching the exact solution: a modular electronic sign where a central controller communicates with individual display units using a "multi-drop scheme." Each unit in Nicholson contains circuitry that stores a unique address, receives its specific portion of image data from the controller, and forwards it to the LED drivers. This circuitry is the claimed "receiver card."
    • Motivation to Combine: A POSITA building the multi-panel display of Guoshi/Kim/Panagotacos would have needed a method to control which part of a larger image is displayed on each individual module. Nicholson provides a well-known, standardized, and effective solution for this exact problem. A POSITA would have been motivated to incorporate Nicholson’s control circuitry to make the display system functional.
    • Expectation of Success: Success would be highly predictable. The modification involves adding a standardized control interface (from Nicholson) to a modular display (from the primary combination), a straightforward integration of complementary technologies.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §314(a) and the Fintiv factors. Petitioner stated its intent to seek a stay of the co-pending district court litigation. It further stipulated that it would not pursue the same grounds in the district court if the IPR is instituted, eliminating concerns of overlapping issues. Petitioner contended that the merits of the petition are particularly strong, especially the anticipation ground based on Guoshi, a reference that was before the Examiner during prosecution but never substantively addressed. Finally, Petitioner asserted it acted diligently in filing the IPR within the one-year statutory bar.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 7, 9, 13, 18, 20, 22-24, 26-28, and 30 of the ’294 patent as unpatentable.