Samsung Electronics Co Ltd v. Lynk Labs Inc

1. Case Identification

• Case #: IPR2021-01576
• Patent #: 10,652,979
• Filed: October 1, 2021
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Lynk Labs, Inc.
• Challenged Claims: 1-18

2. Patent Overview

• Title: AC Driven LED Lighting Devices and Systems
• Brief Description: The ’979 patent discloses light-emitting diode (LED) lighting systems designed to be powered directly from an AC mains voltage source. The technology centers on various configurations of LED packages, driver circuits for AC-to-DC power conversion, and the substrates upon which these components are mounted.

3. Grounds for Unpatentability

Ground 1: Obviousness over Wojnarowski and Martin - Claims 1, 2, 6-8, and 10 are obvious over Wojnarowski in view of Martin.

• Prior Art Relied Upon: Wojnarowski (Patent 6,412,971) and Martin (Application # 2004/0206970).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wojnarowski taught the foundational elements of the challenged claims, including an LED lighting device with an array of series-connected LEDs, a phosphor coating to alter the emitted light, mounting on a flexible substrate, and a driver circuit with a rectifier and filter to convert AC mains power to DC. Petitioner asserted that while Wojnarowski’s driver circuit was described generally, Martin supplied the missing specificity by disclosing a conventional and well-known driver circuit comprising a full-wave bridge rectifier and a capacitor to provide a nearly direct current to an LED array. The combination was alleged to teach matching the total forward voltage drop of the LEDs to the DC output voltage of the driver to ensure stable operation.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Martin’s specific driver circuit with Wojnarowski’s lighting system to implement a predictable, reliable, and efficient method for AC-to-DC conversion. Martin expressly addressed improving bulky and complex prior art devices, which Petitioner argued would have directly motivated a POSITA to apply Martin’s compact, integrated rectifying and filtering solution to Wojnarowski’s system to reduce flicker and improve performance.
  • Expectation of Success: Implementing a standard bridge rectifier and capacitor, as taught by Martin, was a routine and well-understood design choice for powering LEDs from an AC source. Therefore, a POSITA would have had a high expectation of successfully integrating this circuit into Wojnarowski's device.

Ground 2: Obviousness over Wojnarowski, Martin, and Duggal-II - Claims 13-17 are obvious over Wojnarowski in view of Martin and Duggal-II.

• Prior Art Relied Upon: Wojnarowski (Patent 6,412,971), Martin (Application # 2004/0206970), and Duggal-II (Patent 6,800,999).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Wojnarowski/Martin combination for the core LED package and driver circuit elements. The central additional limitation challenged by this ground was mounting the LED chips and power connection leads on a glass substrate. Petitioner contended that while the primary combination disclosed various substrates, Duggal-II explicitly taught the use of glass substrates in analogous AC-powered LED lighting applications.
  • Motivation to Combine: A POSITA, seeking to build the device of Wojnarowski/Martin, would have been motivated to use a glass substrate as it was a common and well-known material option for such applications, as demonstrated by Duggal-II. The choice of substrate material was presented as a predictable design choice from a finite list of known options (e.g., flexible polymers, ceramics, glass), and Duggal-II confirmed the suitability of glass.
  • Expectation of Success: Using a glass substrate was a straightforward and predictable implementation of a conventional material with well-understood optical and physical properties. A POSITA would have had a high degree of confidence in successfully using glass as the mounting substrate.

Ground 3: Obviousness over Wojnarowski, Martin, and Weng - Claims 4, 5, and 12 are obvious over Wojnarowski in view of Martin and Weng.

• Prior Art Relied Upon: Wojnarowski (Patent 6,412,971), Martin (Application # 2004/0206970), and Weng (G.B. Patent No. 2,372,609).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground added the limitations of a "data communication circuit and an antenna" to the base lighting device disclosed by the Wojnarowski/Martin combination. Petitioner argued that Weng taught a "wireless remote control bulb" that included an RF receiver and a "learning/discriminating device." A POSITA would have understood the RF receiver to inherently require an antenna and the learning/discriminating device to function as a data communication circuit for processing remote control codes. Weng also disclosed encapsulating these components within the housing of the light bulb.
  • Motivation to Combine: A POSITA would have been motivated to add the wireless remote control functionality from Weng to the Wojnarowski/Martin lighting device to improve user convenience and expand the product's applications. Adding remote control was a known and desirable feature for consumer lighting products.
  • Expectation of Success: The integration of known remote-control components into a lighting device was a well-established practice. A POSITA would have possessed the skills to implement this modification with a reasonable expectation of predictable success.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations relying on Chen (Patent 6,580,228) for teaching a multi-position dimming switch and Soules-II (WO 2004/021461) for teaching a second lens for protection.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under the Fintiv factors was inappropriate. Key arguments included that no trial date had been set in the parallel district court litigation, which was still in its earliest stages with minimal investment from the parties or the court. Petitioner further noted the IPR challenges all claims (1-18), whereas the litigation involved a subset, and stipulated that it would not pursue in court any grounds on which IPR is instituted.
• Petitioner also argued against denial under 35 U.S.C. §325(d), contending that although some prior art was cited during prosecution (e.g., Chen), it was not substantively analyzed by the examiner. The patent issued after a first office action without any substantive prior art rejection, warranting a thorough review by the Patent Trial and Appeal Board.

5. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 1-18 of the ’979 patent as unpatentable.