PTAB

IPR2021-01220

Samsung Electronics Co Ltd v. Power2B Inc

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1. Case Identification

2. Patent Overview

  • Title: Displays, Interactive Assemblies and User Interface Functionalities
  • Brief Description: The ’675 patent discloses computing devices with touchscreens that use light-sensing technology to detect the position of nearby objects. The system uses an array of detector elements to sense a baseline level of electromagnetic radiation and additional light reflected from an object, determining the object's position when the detected radiation exceeds a predetermined threshold.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yamaguchi, with or without Hinckley - Claims 1, 2, 6, 9-11, and 13 are obvious over Yamaguchi alone or in view of Hinckley.

  • Prior Art Relied Upon: Yamaguchi (Application # 2005/0219229) and Hinckley (Application # 2002/0021278).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yamaguchi discloses all limitations of the challenged claims. Yamaguchi teaches an image display device with a pixel array of light-emitting and photo-detection cells. This system detects an object's position by sensing light emitted from the cells and reflected by the object (e.g., a finger). The position is determined when the detected signal exceeds a predetermined threshold voltage. Yamaguchi also teaches measuring a baseline level of ambient light to eliminate its effect, thereby detecting a change in radiation from the reflected light in addition to the baseline.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Yamaguchi with Hinckley because both address detecting object proximity to a display using reflected light. While Yamaguchi teaches setting a detection threshold, Hinckley provides explicit teachings on quantifying proximity into specific ranges (e.g., defining "close" as less than 7 cm) and using this data for functions like power management. A POSITA would have been motivated to incorporate Hinckley’s method for quantifying proximity to improve the accuracy and add functionality to Yamaguchi’s system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references. Both systems use well-known emitter-detector pairs in predictable ways, and incorporating Hinckley’s specific thresholding ranges into Yamaguchi’s system would be a straightforward implementation of known design principles.

Ground 2: Obviousness over Reime, with or without Hinckley - Claims 1, 2, 6, and 10-13 are obvious over Reime alone or in view of Hinckley.

  • Prior Art Relied Upon: Reime (Application # 2003/0034439) and Hinckley (Application # 2002/0021278).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Reime, a light-based touchpad system, discloses the key elements of the challenged claims. Reime teaches using optical emitters and receivers to detect the presence and track the movement of an object near a touch pad. The system determines an object's location based on changes in the receiver's output signal caused by reflected light. Reime explicitly teaches detecting a baseline level of ambient light and that the signal from reflected light is detected in addition to this baseline. Petitioner contended that setting a threshold for detection at a "substantially zero" signal level after filtering is inherent to Reime's system.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Reime with Hinckley to improve the system's consistency and add features. Reime notes that sensor sensitivity may vary between applications, and Hinckley provides a direct solution by teaching the use of predetermined thresholds to define specific proximity ranges. This would allow for more consistent responses and enable features like power management based on proximity, which Hinckley teaches and would be a desirable addition to Reime's mobile device context.
    • Expectation of Success: A POSITA would expect success in the combination. Reime already compares a filtered signal to zero; modifying this to compare against a different predetermined threshold as taught by Hinckley is a simple arithmetic operation. Both references propose predictable solutions to common problems in the field using similar hardware.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under the Fintiv factors. The core arguments were that the parallel district court proceeding was in its earliest stages, with minimal investment from the parties or the court, as no claim construction, substantive orders, or significant discovery had occurred. Petitioner asserted it acted diligently by filing the IPR petition approximately two months after receiving preliminary infringement contentions. Furthermore, Petitioner stipulated that it would not pursue in the district court any invalidity ground raised or that could have been reasonably raised in this IPR, significantly reducing any potential overlap and promoting judicial efficiency. Petitioner also contended that the strong merits of the unpatentability grounds weighed heavily in favor of institution.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 6, and 9-13 of the ’675 patent as unpatentable under 35 U.S.C. §103.