PTAB

IPR2021-01239

Samsung Electronics Co Ltd v. Power2B Inc

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Petition

1. Case Identification

2. Patent Overview

  • Title: Integrated Display and Input Device
  • Brief Description: The ’850 patent discloses integrated displays and input devices that use optical sensors to detect the presence of a nearby object. The system includes a pixel array, at least one sensor to detect an object within a "predetermined degree of propinquity," and circuitry to provide a non-imagewise input representing the object's position relative to the array.

3. Grounds for Unpatentability

Ground 1: Obviousness over Reime and Hinckley - Claims 15-18, 21-22, 26, 30, 31, and 41 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 argued that Reime discloses the core elements of independent claim 15. Reime teaches an integrated display and input device, such as a mobile phone, with a touch pad area that can be an LCD panel (the claimed "pixel array"). Reime’s device uses optical sensor components (light emitters and receivers) arranged at the edge of the display to detect a nearby object (e.g., a finger) and determine its two-dimensional coordinates. Circuitry, including a microprocessor, receives the sensor output and provides a non-imagewise signal representing the object's position. To the extent Reime does not explicitly teach a "predetermined degree of propinquity," Petitioner asserted Hinckley supplies this limitation. Hinckley discloses a mobile device with proximity sensors and explicitly teaches using predetermined signal thresholds to define distinct proximity ranges, such as a range of 0-7 cm to be considered "close." For dependent claim 26, which requires a "second predetermined threshold," Petitioner pointed to Hinckley’s disclosure of two thresholds (e.g., sensor values of 50 and 180) to define different ranges like "Close," "InRange," and "OutOfRange."
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings of Reime and Hinckley to improve the functionality and sensitivity of Reime's device. Reime acknowledges that sensor sensitivity may vary between applications, and Hinckley provides a well-understood method for quantifying proximity using predetermined thresholds to enable predictable features like power management or activating an audio receiver, which are desirable improvements for the mobile devices disclosed in Reime.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success, as the combination involves applying Hinckley’s predictable thresholding technique to the sensor output of a conventional optical sensing system like Reime’s to achieve the known benefit of quantified proximity detection.

Ground 2: Obviousness over Yamaguchi and Hinckley - Claims 31 and 41 are obvious over Yamaguchi, alone or in view of Hinckley.

  • Prior Art Relied Upon: Yamaguchi (Application # 2005/0219229) and Hinckley (’278 application).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yamaguchi discloses the key elements of independent claim 31. Yamaguchi teaches an image display device with a pixel array where each pixel includes a light-emitting and photo-detection cell. This system senses the position of a nearby object by detecting reflected light, determining a baseline ambient light level to eliminate its effect, and comparing the resulting signal to a "predetermined threshold voltage." This directly teaches a pixel array with integrated detectors sensing position based on exceeding a threshold relative to a baseline. To the extent Yamaguchi’s teaching of detecting an object in "close proximity" is insufficient for the "predetermined degree of propinquity" limitation, Petitioner again relied on Hinckley’s explicit disclosure of defining nearness using predetermined sensor value ranges.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to modify Yamaguchi with Hinckley's teachings to enhance accuracy and add functionality. Yamaguchi suggests its detection threshold can be adjusted based on the purpose of the detection, and Hinckley provides a specific, known method for setting thresholds to define proximity ranges, which could improve accuracy and enable features like power saving—a goal also mentioned by Yamaguchi.
    • Expectation of Success (for §103 grounds): Success would be reasonably expected because the combination involves implementing a known method for quantifying proximity (from Hinckley) in a system that already uses threshold-based light detection to sense object position (Yamaguchi).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise discretionary denial under Fintiv. The core arguments were that the parallel district court litigation was in a nascent stage, with minimal investment from the court and parties, as discovery and claim construction had not begun. Petitioner also stipulated that it would not pursue invalidity in the district court using any obviousness ground that includes the primary references from this IPR, thereby minimizing overlap. Finally, Petitioner noted that it challenges more claims in the IPR than are asserted in the parallel litigation, making the IPR the only venue for those challenges.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 15-18, 21, 22, 26, 30, 31, and 41 of the ’850 patent as unpatentable.