PTAB

IPR2021-01289

Apple Inc v. GUI Global Products Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus for Cleaning View Screens and Lenses and Method for the Use Thereof
  • Brief Description: The ’020 patent discloses a system comprising a portable electronic device and a portable switching device. The switching device is configured to selectively and detachably couple to the electronic device via magnetic force and can activate, deactivate, or hibernate the electronic device.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-9, 11-15, and 19 over Kim

  • Prior Art Relied Upon: Kim (Application # 2010/0227642).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim, which teaches a mobile terminal system with a main device and one or more detachable sub-devices, discloses or suggests every limitation of the challenged claims. Specifically, Petitioner contended that Kim’s watch-type main device embodiment serves as the “portable electronic device,” and its detachable “sub-device” is the claimed “portable switching device.” Kim explicitly teaches that the sub-device can control the main device’s power state (e.g., turn the display on/off) based on its coupling status, thus functioning as a switching device. Kim also discloses that the coupling mechanism between the main device and sub-device can be magnets, satisfying the magnetic coupling limitation.
    • Motivation to Combine: The argument relied on combining features described across different embodiments within Kim itself. Petitioner asserted a person of ordinary skill in the art (POSITA) would be motivated to do so because Kim explicitly states its disclosed embodiments “may be used singly and/or by being combined together.” For example, a POSITA would combine the magnetic coupling taught for a folder-type device with the watch-type device to achieve a predictable, detachable coupling.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success in combining these features, as it would involve applying known coupling techniques (magnets) to a similar device (a watch-type form factor) to achieve the predictable result of a secure, detachable connection.

Ground 2: Obviousness of Claim 10 over Kim in view of Koh

  • Prior Art Relied Upon: Kim (Application # 2010/0227642) and Koh (Korean Patent Publication 10-2008-0093178).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claim 10, which requires the switching device to be “wireless earplugs.” Petitioner argued that while Kim discloses its sub-device can be configured as an “ear phone” or “Bluetooth headset,” it lacks implementation details. Koh remedies this by disclosing a portable electronic device module in the form of a wireless headset that detachably couples to a watch-type storage unit worn on a user’s wrist.
    • Motivation to Combine: A POSITA, seeking to implement Kim’s suggestion of an earphone sub-device, would have been motivated to look to references like Koh that solve the specific problem of coupling a wireless headset to a watch-type device. Koh provides the exact details missing from Kim for implementing this functionality, teaching both magnetic and mechanical (protrusion/groove) coupling methods.
    • Expectation of Success: Combining the references would involve incorporating Koh’s specific, compatible coupling techniques into Kim’s analogous system to create a functional and predictable product.

Ground 3: Obviousness of Claims 16 & 17 over Kim in view of Lee

  • Prior Art Relied Upon: Kim (Application # 2010/0227642) and Lee (Application # 2010/0298032).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground challenges claims 16 and 17, which relate to using magnets to actuate the electronic circuit. Petitioner asserted that Kim discloses that coupling the sub-device (with its magnet) actuates the main device’s circuit (e.g., turns the display on). Lee discloses using a Hall sensor to detect the proximity of a magnet to sense the open/closed state of a folding mobile device and actuate its electronics accordingly.
    • Motivation to Combine: A POSITA would combine Kim and Lee to implement the magnetic actuation function described generally in Kim using the specific and well-understood Hall sensor mechanism taught by Lee. Both references are directed to similar mobile devices, making Lee’s sensing solution directly applicable to Kim’s system for detecting the coupling status of the sub-device.
    • Expectation of Success: The combination would predictably yield a system where the magnet in Kim’s sub-device actuates a Hall sensor in the main device to control its state, a common and reliable technique in the art.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 18 over Kim in view of Jiang (Patent 5,946,121), which allegedly added a laser to the switching device.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) based on Fintiv and General Plastic factors would be inappropriate. This petition was filed as a "copycat" of an already-instituted inter partes review (IPR) filed by another party (Samsung, IPR2021-00335) and conditionally requested joinder to that proceeding. Petitioner argued that institution would promote efficiency by confining adjudication of the patent's validity to a single forum, as the parallel district court litigation was in its infancy and the parties had agreed to seek a stay pending the IPR outcome.

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-19 of the ’020 patent as unpatentable under 35 U.S.C. §103.