PTAB

IPR2021-00470

Apple Inc v. GUI Global Products Ltd

Key Events

Petition

petition Intelligence

Title: APPARATUS FOR CLEANING VIEW SCREENS AND LENSES AND METHOD FOR THE USE THEREOF
Brief Description: The ’020 patent relates to a system comprising a portable switching device (e.g., wireless earbuds) and a portable electronic device (e.g., a charging case). The devices are configured to selectively couple using magnetic force, and the switching device’s interaction with the electronic device can cause the electronic device to activate, deactivate, or enter a hibernation state.

Prior Art Relied Upon: Bohbot (French Patent Publication No. FR2912858) and Gundlach (Application # 2008/0132293).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Bohbot taught a "miniature communication device" system comprising a primary module (the claimed "portable electronic device") and a detachable headset (the "portable switching device") that couple magnetically. Gundlach taught a case or cradle with a contoured recess for storing a wireless headset. The combination of Bohbot's system with Gundlach's contoured recess allegedly met the limitations of independent claim 1, including the two cases, magnetic coupling, and complementary surface elements (the recess). Dependent claims were allegedly met by Bohbot’s teachings of view screens and wireless earplugs, and Gundlach’s teachings of a hinged lid.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Gundlach’s protective contoured recess with Bohbot’s device to provide robust protection for the headset. This would prevent detachment from jostling or dropping, complementing Bohbot's stated goal of avoiding headset loss.
- Expectation of Success: Petitioner asserted that combining these known elements would yield a predictable result, as the storage and charging functions of both references would work together as they did independently.

Prior Art Relied Upon: Bohbot, Gundlach, and Li (Chinese Patent Publication No. CN201114710Y).
Core Argument for this Ground:
- Prior Art Mapping: This ground builds on the Bohbot and Gundlach combination by adding Li, which taught a Bluetooth earphone with a "laser LED module" and a "keyboard module." Petitioner contended that Li’s teachings disclosed using the headset to perform functions like adjusting volume, making calls, and providing a laser pointer. These features allegedly rendered obvious claim 19 (controlling volume), claim 18 (comprising a laser), and claim 4 (having a lens, as a POSITA would know lasers require collimating lenses).
- Motivation to Combine: A POSITA would have been motivated by market forces and consumer demand to integrate Li's functionalities into the Bohbot-Gundlach headset. Adding remote volume control and a laser pointer would predictably improve the headset's utility and user flexibility.
- Expectation of Success: Petitioner argued it would be a predictable result to add known remote-control and laser pointer features to a wireless headset to improve its functionality.

Prior Art Relied Upon: Bohbot, Gundlach, and Diebel (Application # 2010/0124040).
Core Argument for this Ground:
- Prior Art Mapping: This ground was presented as substantively identical to Ground 1A, but it relied on Diebel to satisfy the limitation of claim 1[f] that the switching device is configured to "activate, deactivate or send into hibernation the portable electronic device." Diebel taught a case for an electronic device that enters an "extended sleep mode" (hibernation) to conserve power when the device is not connected, and exits that mode (activates) upon connection.
- Motivation to Combine: A POSITA would combine Diebel's power-saving feature with the Bohbot-Gundlach system to achieve the well-known and beneficial goal of extending battery life for a portable electronic device.
- Expectation of Success: Petitioner contended that integrating a known power-saving sleep mode into a portable charging system was a routine design choice with predictable benefits.
Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Bohbot and Gundlach with Nishikawa (for a lens-equipped LED), Stevinson (for a magnetic lid fastener), Rosener (for a true wireless stereo earbud design), and Iio (for actuating an electronic circuit via a magnet in the lid).

Petitioner argued extensively that discretionary denial under either 35 U.S.C. §325(d) or §314(a) would be inappropriate.
§325(d) (Same or Substantially Same Art): Petitioner argued that the prior art references asserted in the petition were not considered by the examiner during prosecution, and no substantially similar art was applied.
§314(a) (General Plastic Factors): The petition was filed six weeks after a separate IPR filed by Samsung. Petitioner argued it is a direct market competitor to Samsung, not a related party, and that its petition relies on entirely different prior art, presenting no road-mapping concerns or unfair prejudice to the Patent Owner.
§314(a) (Fintiv Factors): Petitioner contended that the parallel district court litigation was in its infancy, with no trial date set and key deadlines months away. Therefore, the Board’s Final Written Decision would issue long before a potential trial. Petitioner further eliminated any risk of duplicative efforts by stipulating that it would not pursue the petition’s invalidity grounds in district court if the IPR is instituted.

Petitioner requests institution of an inter partes review and cancellation of claims 1-10 and 16-19 of Patent 10,259,020 as unpatentable.