Samsung Electronics Co Ltd v. Power2B Inc

1. Case Identification

• Case #: IPR2021-01257
• Patent #: 9,317,170
• Filed: July 14, 2021
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Power2B Inc.
• Challenged Claims: 1-2, 6-8, 13-14, 16, 18-19, 21-23, 26, and 30

2. Patent Overview

• Title: Displays, Interactive Assemblies and User Interface Functionalities
• Brief Description: The ’170 patent discloses interactive assemblies, such as touchscreens, that use light sensing to detect the position of nearby objects. The technology involves detector elements arranged at an edge of an interactive surface that sense an object's impingement on electromagnetic signals and compare the detected signal to a predetermined threshold to determine the object's location.

3. Grounds for Unpatentability

Ground 1: Obviousness over Newton and Hinckley - Claims 1-2, 13-14, 18, 21, 26, and 30 are obvious over Newton alone or in view of Hinckley.

• Prior Art Relied Upon: Newton (Application # 2002/0118177) and Hinckley (Application # 2002/0021278).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Newton, a touch-panel display system, discloses nearly all elements of the independent claims. Newton taught an interactive surface with at least two distinct functional regions (e.g., different travel option buttons), with infrared (IR) emitters and detectors arranged around the edges of the display. These sensors detected an object by sensing the interruption of a web of energy beams. Newton also described utilization circuitry to process the sensor outputs and a support substrate (housing) for the detector assembly. Petitioner asserted Newton’s “detection map,” created when the screen is untouched, met the limitation of detecting radiation at a baseline level.
  • Motivation to Combine: To the extent Newton did not explicitly teach using multiple, predetermined thresholds for proximity detection, Petitioner contended a person of ordinary skill in the art (POSITA) would combine Newton with Hinckley. Hinckley taught a method for using multiple, distinct thresholds with an IR proximity sensor to define different operational ranges (e.g., “Close,” “InRange,” “OutOfRange”). A POSITA would combine Hinckley’s thresholding logic with Newton’s display system to gain known benefits, such as improved power efficiency by changing device states based on proximity, a feature explicitly taught by Hinckley.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because both references employed well-understood IR sensor technology. Implementing Hinckley’s predictable software-based thresholding logic within Newton’s hardware framework was presented as a straightforward and predictable combination.

Ground 2: Obviousness over Reime and Hinckley - Claims 1-2, 6-8, 13, 16, 18-19, 21-23, 26, and 30 are obvious over Reime 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 Reime taught a touch-sensitive device that used reflected light to detect an object’s presence and location. Reime disclosed an interactive surface with multiple regions of different functionalities (e.g., “ON”/“OFF” functions), with optical emitters and receivers located in proximity to, and at the edge of, the interactive surface (e.g., an LCD panel). The detector assembly was mounted on a support substrate (a printed circuit board). Petitioner argued that Reime’s disclosure of measuring ambient light to establish a baseline signal met the corresponding claim limitation. The system’s circuitry then detected a change from this baseline caused by light reflected from a user’s finger or a stylus.
  • Motivation to Combine: Petitioner contended a POSITA would be motivated to combine Reime with Hinckley to improve the system's functionality. Reime noted that sensor sensitivity and response may vary between applications. Hinckley provided a direct solution by teaching the use of predetermined thresholds to ensure consistent responses and enable additional features based on defined proximity ranges. A POSITA would incorporate Hinckley’s thresholding to make Reime’s device more robust and to add power-saving features, such as those Hinckley taught for mobile devices.
  • Expectation of Success: Success was expected because the combination involved applying a known signal processing technique (Hinckley’s thresholds) to a standard IR sensor output (from Reime’s system). Petitioner argued this represented a predictable application of known principles to achieve an expected result.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise discretionary denial under 35 U.S.C. §314(a) based on the Fintiv factors. The co-pending district court litigation was in its very early stages, with minimal investment from the parties or the court, as discovery and claim construction had not begun. Petitioner also filed a stipulation agreeing not to pursue in the district court any invalidity ground that includes the primary references from this inter partes review (IPR), thereby minimizing overlap between the proceedings. Finally, Petitioner asserted the strong merits of the petition, particularly the obviousness arguments based on Newton, weighed heavily against denial and in favor of institution to promote patent quality.

5. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-2, 6-8, 13-14, 16, 18-19, 21-23, 26, and 30 of Patent 9,317,170 as unpatentable under 35 U.S.C. §103.