PTAB

IPR2021-00335

Samsung Electronics Co Ltd v. GUI Global Products Ltd

Key Events

Petition

petition Intelligence

Title: System and Method for Cleaning an Electronic Device View Screen
Brief Description: The ’020 patent discloses a system comprising a portable switching device that selectively couples to a portable electronic device. The coupling mechanism employs magnetic force, and the switching device is configured to activate, deactivate, or hibernate the electronic device.

Prior Art Relied Upon: Kim (Application # 2010/0227642).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kim discloses a mobile terminal system with a "main device" and a detachable "sub-device," which correspond to the claimed "electronic device" and "switching device," respectively. Petitioner asserted that it would have been obvious to a POSITA to combine features from Kim’s various disclosed embodiments, such as applying the magnetic coupling members of a folder-type device to Kim's watch-type device. Kim’s sub-device is configured to change the operational state of the main device upon coupling or decoupling (e.g., turning the display on or off), thus meeting the limitation for the switching device to activate/deactivate the electronic device.
- Motivation to Combine: A POSITA would have been motivated to combine different embodiments within Kim (e.g., applying magnetic coupling to the watch-type device) as it amounted to using a known technique disclosed in the reference to improve a similar device for predictable results.
- Expectation of Success: Petitioner contended a POSITA would have had an expectation of success because Kim explicitly teaches that magnets are an effective and known technique for coupling a sub-device to a main device.

Prior Art Relied Upon: Kim (Application # 2010/0227642) and Koh (Korean Patent Publication 10-2008-0093178).
Core Argument for this Ground:
- Prior Art Mapping: This ground addresses claim 10, which requires the switching device to be "wireless earplugs." Petitioner asserted that while Kim discloses its sub-device can be an "ear phone" or "Bluetooth headset," it lacks implementation details. Koh was argued to cure this deficiency by teaching a wireless headset that detachably couples to a wrist-worn storage unit using both magnets and mechanical protrusions/grooves.
- Motivation to Combine: A POSITA seeking to implement the wireless earphone sub-device suggested in Kim would have been motivated to look to references like Koh. Koh provided a known and detailed technique for detachably coupling a wireless headset to a device with a watch-type form factor, which is analogous to Kim’s system.
- Expectation of Success: Combining Kim’s system with Koh's specific coupling method for a similar device would predictably yield a functional, wrist-mounted device with detachable wireless earplugs.

Prior Art Relied Upon: Kim (Application # 2010/0227642) and Lee (Application # 2010/0298032).
Core Argument for this Ground:
- Prior Art Mapping: This ground targets claims requiring a magnet to actuate an electronic circuit. Petitioner argued that Kim discloses a sub-device with a magnet that changes the main device's state upon coupling. Lee teaches the specific implementation of using a Hall sensor to detect the proximity of a magnet to determine if a folding device is open or closed, thereby actuating a circuit.
- Motivation to Combine: A POSITA would combine these references because Lee provides a specific, well-known, and compatible implementation (a Hall sensor) for achieving the general function disclosed in Kim (detecting magnetic coupling to change device state).
- Expectation of Success: Using a standard Hall sensor to detect a magnet's presence to trigger an electronic circuit was a well-understood and predictable technique, ensuring a high expectation of success.

Prior Art Relied Upon: Kim (Application # 2010/0227642) and Jiang (Patent 5,946,121).
Core Argument for this Ground:
- Prior Art Mapping: This ground addresses claim 18, which requires the switching device to comprise a laser. Petitioner argued that Kim discloses wireless communication between its devices via protocols like Infrared Data Association (IrDA). Jiang teaches an improved IrDA module that uses a Vertical Cavity Surface Emitting Laser (VCSEL) instead of a conventional LED to improve energy efficiency and communication speed in portable devices.
- Motivation to Combine: A POSITA would be motivated to incorporate Jiang's laser-based IrDA module into Kim's portable device to solve the known problems of high power consumption and slow speed associated with traditional LED-based IrDA systems.
- Expectation of Success: Success would be expected, as the combination amounted to substituting a known, improved component (Jiang's laser module) for a conventional component within Kim's disclosed system to achieve predictable performance benefits.

Priority Date Challenge: A central contention of the petition is that the challenged claims are not entitled to a priority date earlier than November 3, 2011. Petitioner argued that the earlier-filed provisional application (the ’752 provisional application) fails to provide adequate written description for key limitations of claim 1, such as "a portable switching device" and its function to activate/deactivate the electronic device. This argument is critical to establishing Kim, published in 2010, as valid prior art.

Fintiv Factors Favor Institution: Petitioner argued that discretionary denial under §314(a) based on Fintiv is inappropriate. The parallel district court litigation against Samsung was partially stayed, and Petitioner noted that even under the Patent Owner's proposed schedule, a trial would not occur until at least eight months after a Final Written Decision (FWD) in this IPR. Consequently, Petitioner contended there had been minimal investment in the parallel proceeding and that the IPR would be a more efficient resolution, particularly since Samsung challenges all claims of the ’020 patent, whereas fewer claims are asserted in the district court.

Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’020 patent as unpatentable.