PTAB

IPR2021-00336

Samsung Electronics Co Ltd v. GUI Global Products Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System with Portable Switching Device
  • Brief Description: The ’021 patent discloses a system comprising a portable switching device and a portable electronic device. The core concept involves a switching device, such as a watch-type device, that is configured to selectively couple to a separate electronic device (e.g., a sub-device) using magnetic force and to activate, deactivate, or send the electronic device into hibernation.

3. Grounds for Unpatentability

Ground 1: Claims 1-9, 11-15, and 19 are obvious over Kim

  • Prior Art Relied Upon: Kim (Application # 2010/0227642).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim teaches a mobile terminal system comprising a main device and one or more detachable sub-devices, which directly map to the claimed "portable switching device" and "portable electronic device." Kim’s disclosure of a watch-type main device with a folding body and a sub-device that detachably couples to it was asserted to meet the structural limitations of claim 1. Petitioner contended that Kim discloses that coupling can be achieved via magnets, satisfying the "employing magnetic force" limitation. Furthermore, Kim was argued to teach that the main device detects the coupling status of the sub-device and changes its operational state accordingly, thus disclosing the claimed function of activating or deactivating the electronic device.
    • Motivation to Combine (for §103 grounds): The argument centered on combining features disclosed across different embodiments within Kim itself. Petitioner asserted a person of ordinary skill in the art (POSITA) would find it obvious to apply the features of Kim’s folder-type device (e.g., magnetic coupling) to its watch-type device, as Kim suggests its embodiments "may be used singly and/or by being combined together." This would be a predictable modification to improve a similar device using a known technique disclosed in the same reference.
    • Expectation of Success: A POSITA would have an expectation of success because Kim explicitly teaches that magnets are an effective technique for coupling a sub-device to a main device. The combination of features from Kim’s analogous embodiments was presented as a straightforward application of disclosed principles.

Ground 2: Claim 10 is obvious over Kim in view of Koh

  • 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 addressed claim 10, which requires the electronic device to be "wireless earplugs." Petitioner asserted that Kim discloses its sub-device can be configured as an "ear phone" or a "Bluetooth headset" but lacks specific implementation details for coupling it to a watch-type main device. Koh was introduced as teaching a portable module comprising a wireless headset that detachably couples to a wrist-worn storage unit using both magnetic and mechanical (sliding groove) features.
    • Motivation to Combine: A POSITA, seeking to implement Kim's disclosure of a headset sub-device for its watch-type main device, would be motivated to consult Koh. Koh provides a detailed and compatible solution for detachably coupling a wireless headset to a watch-type device, addressing the very problem posed by Kim. The combination would yield the predictable result of a functional watch with integrated, detachable wireless earbuds.
    • Expectation of Success: Success would be expected as both references relate to portable, wrist-worn electronics and compatible coupling mechanisms (magnets, mechanical interlocks). Combining them would involve applying Koh’s specific coupling solution to Kim’s analogous system.

Ground 3: Claims 16 & 17 are obvious over Kim in view of Lee

  • Prior Art Relied Upon: Kim (Application # 2010/0227642) and Lee (Application # 2010/0298032).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted claims 16 and 17, which require a magnet to be "employed in actuating the electronic circuit." While Kim teaches actuation upon coupling, Petitioner argued it does not specify the mechanism. Lee was presented as disclosing a mobile device with a folding-type form factor that uses a Hall sensor to detect the proximity of a magnet, thereby sensing whether the device is open or closed and actuating a circuit in response.
    • Motivation to Combine: A POSITA implementing Kim's system would be motivated to use a known, reliable method for detecting the proximity of the magnetic sub-device. Lee provides an explicit teaching of using a Hall sensor and magnet for this exact purpose in a comparable device. This combination would provide a reliable mechanism for the actuation function generally described in Kim.
    • Expectation of Success: The combination was presented as predictable, as it involves integrating a standard electronic component (Hall sensor) taught by Lee into the compatible system of Kim to achieve a disclosed function (actuation based on proximity).

Ground 4: Claim 18 is obvious over Kim in view of Jiang

  • Prior Art Relied Upon: Kim (Application # 2010/0227642) and Jiang (Patent 5,946,121).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 18, which adds a "laser" to the switching device. Petitioner pointed to Kim’s disclosure of a short-range communication module, such as Infrared Data Association (IrDA), for wireless communication between the main device and sub-device. Jiang was introduced for its teaching of using a vertical cavity surface emitting laser (VCSEL) as a light source in an IrDA data link.
    • Motivation to Combine: A POSITA would be motivated to improve the IrDA communication in Kim’s portable system. Jiang explicitly teaches that using a VCSEL instead of a conventional LED is "ideal for portable use" because it significantly reduces power consumption and improves communication speed—two critical concerns for battery-powered portable devices like those in Kim.
    • Expectation of Success: Success would be expected as Jiang’s VCSEL is presented as a superior, drop-in replacement for a standard component in an IrDA module, offering the predictable benefits of improved efficiency and performance for the system disclosed in Kim.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention of the petition was that the challenged claims are not entitled to a priority date earlier than November 3, 2011. Petitioner argued that the earlier '752 provisional application fails to provide adequate written description for key limitations of claim 1, including the "portable switching device" itself, the magnetic coupling, and the function of activating or deactivating the electronic device. This argument was critical to establishing Kim, Koh, and Lee as prior art under 35 U.S.C. §102.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial of institution under §314(a) based on the Fintiv factors would be inappropriate. The key reasons asserted were that the parallel district court proceeding was partially stayed, and any potential trial date was scheduled for at least eight months after the statutory deadline for a Final Written Decision (FWD) in the inter partes review (IPR). Petitioner also contended that the investment in the parallel litigation was minimal and that the petition presented a particularly strong case on the merits, which weighs heavily in favor of institution. Further, it was argued that denial under §325(d) was unwarranted as no cited references had been previously considered by the USPTO.

6. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-19 of the ’021 patent as unpatentable.