PTAB

IPR2021-01266

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 ’093 patent discloses an integrated display and input device, such as for a mobile device, featuring a pixel array for visual output and at least one optical sensor. The sensor is designed to detect the position of a nearby object (e.g., a finger) when it is within a "predetermined degree of propinquity," and circuitry provides a non-imagewise input representing the object's position to utilization circuitry.

3. Grounds for Unpatentability

Ground 1: Obviousness over Reime and Hinckley - Claims 1, 5, 8, 11-13, 26, 29, 36-38, 44, 45-46, 48, 49, and 56-58 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 limitations of independent claims 1 and 44. Reime teaches an integrated touch-sensitive device with a liquid crystal display (LCD) serving as the claimed "pixel array." This device uses optical emitters and receivers (the claimed "sensor") arranged peripherally to the display to detect the presence and position of a nearby object using reflected light, including infrared (IR) light. Reime's system includes a backlight for the LCD (the "illuminator") and processing circuitry that receives sensor output and provides non-imagewise "measurement information" regarding the object's position to a microprocessor (the "utilization circuitry"). Petitioner asserted that Reime also discloses detecting a baseline ambient light level and comparing sensor signals against a threshold (substantially zero after high-pass filtering) to determine object presence.
    • Motivation to Combine (for §103 grounds): Petitioner contended that, to the extent Reime does not explicitly teach a "predetermined degree of propinquity" or using multiple signal thresholds, a person of ordinary skill in the art (POSITA) would look to Hinckley. Hinckley explicitly teaches using proximity sensor output to define specific ranges of nearness (e.g., "close" vs. "out of range") based on predetermined signal thresholds. A POSITA would combine Hinckley's quantitative approach with Reime's system to improve functionality, such as for power management or to provide more consistent responses, which were known benefits in the art.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success because both references address the same problem in the same field (proximity sensing for mobile devices) using predictable and well-understood optical sensor technology.

Ground 2: Obviousness over Reime, Hinckley, and Eliasson - Claim 48 is obvious over Reime and Hinckley, further in view of Eliasson.

  • Prior Art Relied Upon: Reime (Application # 2003/0034439), Hinckley (Application # 2002/0021278), and Eliasson (WO 2005/026938).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addressed the limitation in dependent claim 48 requiring that light reflected by an object is "transmitted through the viewing plane defining plate directly to the at least one sensor element." Petitioner argued that while Reime discloses a cover plate that functions as a light guide, Eliasson provides a more explicit teaching of a transmissive plate designed to guide reflected light via internal reflection directly to a detector positioned at its edge.
    • Motivation to Combine (for §103 grounds): Reime acknowledged that its optical receivers can become saturated by ambient light, which interferes with detecting a touching object. Eliasson's design, which guides light directly to the sensor, was expressly taught as a solution to prevent excess ambient light from "'blinding' the detector." A POSITA, facing the known problem of ambient light saturation described in Reime, would be motivated to incorporate Eliasson's direct light-guiding plate design to improve the reliability and accuracy of Reime's sensor system.
    • Expectation of Success (for §103 grounds): The combination would have been predictable because it involves integrating well-known optical components (light guides, sensors, displays) to solve a commonly understood problem in the field.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) based on the Fintiv factors. The core arguments were:
    • The parallel district court proceeding was in a very early stage, with minimal investment by the court and parties, no substantive orders issued, and the trial date was more than a year away.
    • Petitioner stipulated that it would not pursue in the district court any invalidity ground that includes the primary references asserted in the petition, mitigating concerns of duplicative efforts.
    • The merits of the petition are exceptionally strong, as Reime alone teaches nearly all claim elements, and the proposed combinations address known problems with predictable solutions.
    • The petition is part of a co-pending challenge against a related patent (’850 patent) with similar claims and prior art, making IPR an efficient venue for resolving the overlapping validity issues.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1, 5, 8, 11-13, 26, 29, 36-38, 44, 45-46, 48, 49, and 56-58 of the ’093 patent as unpatentable under 35 U.S.C. §103.