PTAB

IPR2022-00090

LG Electronics Inc v. Gesture Technology Partners LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Computer Input Device and Method
  • Brief Description: The ’079 patent describes computer input devices that use cameras and light sources to optically sense human positions and gestures. The disclosed systems can be integrated into devices like laptop computers to detect gestures such as pointing, pinching, and gripping within a defined work volume above a keyboard.

3. Grounds for Unpatentability

Ground 1: Obviousness over Numazaki - Claims 1, 2, 4-14, 17, 19, 21-22, 24-28, and 30 are obvious over Numazaki in view of the knowledge of a Person Having Ordinary Skill in the Art (PHOSITA).

  • Prior Art Relied Upon: Numazaki (Patent 6,144,366).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Numazaki, which was not considered during prosecution, discloses the core limitations of the challenged claims. Specifically, Numazaki’s eighth embodiment teaches a laptop computer ("note PC") with an integrated lighting unit and a "photo-detection sensor unit" (camera) positioned above the keyboard. This system is oriented to observe a "work volume" where a user can perform pointing gestures with their hand to control a cursor or perform "click and drag" operations, satisfying the limitations of independent claims 1, 11, and 21. For dependent claims, Petitioner asserted that other embodiments in Numazaki teach analyzing sequential images to track finger movement (claim 4) and determining the 3D position of the hand (claim 8), and that a PHOSITA would have found it obvious to incorporate these known techniques.
    • Motivation to Combine (for §103 grounds): A PHOSITA would have been motivated to apply features from Numazaki's general embodiments to its specific laptop embodiment to improve performance. For example, using an LED as the light source, as taught in Numazaki’s first embodiment, would be an obvious design choice to improve power efficiency and instantaneous illumination for the portable laptop system.
    • Expectation of Success (for §103 grounds): A PHOSITA would have had a high expectation of success in applying these known techniques and features, as they were used to improve similar devices and solve predictable problems like power consumption in portable electronics.

Ground 2: Obviousness over Numazaki and Numazaki ’863 - Claims 3, 15, and 23 are obvious over Numazaki in view of Numazaki ’863.

  • Prior Art Relied Upon: Numazaki (Patent 6,144,366) and Numazaki ’863 (Patent 5,900,863).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addresses claims requiring a light source with a plurality of light-emitting diodes. While Numazaki teaches using a single LED, Numazaki ’863—from the same inventor and assignee—explicitly discloses a data input apparatus using a "two-dimensional LED array" as part of a range-finding system to detect the distance to an operator's hand with high accuracy.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the LED array from Numazaki ’863 with the laptop gesture system of Numazaki to improve the system's ability to calculate distances and accurately detect small hand and finger movements. This modification would enhance the gesture recognition capabilities already contemplated by Numazaki.
    • Expectation of Success (for §103 grounds): Success would be expected because the combination involves applying a known range-finding technique, disclosed by the same inventor in a nearly identical system, to achieve the predictable result of improved 3D gesture detection.

Ground 3: Obviousness over Numazaki and DeLuca - Claims 16 and 29 are obvious over Numazaki in view of DeLuca.

  • Prior Art Relied Upon: Numazaki (Patent 6,144,366) and DeLuca (Patent 6,064,354).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses claims requiring a three-dimensional display. DeLuca discloses a computer system that stereoscopically projects a 3D interface image into a space where a user can interact with virtual objects (e.g., icons) by moving their finger to "touch" the projected icon.
    • Motivation to Combine (for §103 grounds): A POSITA would combine DeLuca's 3D display technology with Numazaki’s 3D gesture-sensing laptop system. Petitioner argued this combination would create a more intuitive user experience, as Numazaki already detects a user's hand in three dimensions, and projecting the interface in 3D is a logical next step to improve usability.
    • Expectation of Success (for §103 grounds): A PHOSITA would expect success because the modification simply incorporates a known type of display technology into a system already capable of 3D input, a straightforward integration of complementary technologies.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claim 18 is obvious over Numazaki in view of DeLeeuw (Patent 6,008,018) for teaching a pinch gesture, and claim 20 is obvious over Numazaki in view of Maruno (Patent 6,191,773) for teaching a grip gesture.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The parallel district court litigation had only recently been transferred and was in its earliest stages, with no trial date set and minimal investment by the parties or the court. Petitioner contended that the trial would occur well after the Board’s Final Written Decision (FWD). Furthermore, Petitioner offered to stipulate that it would not pursue the same invalidity grounds in the district court if the IPR was instituted, mitigating concerns of overlap and inefficiency. Petitioner also argued that the merits of the petition are exceptionally strong and that the Fintiv framework itself exceeds the Director’s statutory authority and is arbitrary and capricious.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’079 patent as unpatentable.