Samsung Electronics Co Ltd v. Lynk Labs Inc

1. Case Identification

• Case #: IPR2022-00150
• Patent #: 10,687,400
• Filed: November 12, 2021
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Lynk Labs, Inc.
• Challenged Claims: 1-6, 21-26

2. Patent Overview

• Title: LED Lighting Systems and Devices
• Brief Description: The ’400 patent discloses lighting systems and devices that use light-emitting diodes (LEDs). The claimed invention involves a lighting system with a data communication circuit, including an LED circuit and an antenna, integrated into a lighting device that can communicate with a portable telecommunications device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Piepgras, Michael, and Butler - Claims 1-4 are obvious over Piepgras, Michael, and Butler.

• Prior Art Relied Upon: Piepgras (Application # 2003/0137258), Michael (Patent 4,656,398), and Butler (Application # 2003/0035075).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Piepgras taught a lighting system with a spotlight and a remote user interface for wireless control via a radio frequency (RF) link, including an LED circuit and a transceiver. However, Piepgras did not explicitly disclose that its data communication circuit comprised both the LED circuit and an antenna. Michael allegedly cured this deficiency by teaching an LED lighting assembly with a remote control that uses an antenna for wireless communication. Petitioner contended that combining these references rendered most limitations of claim 1 obvious. To address the final limitation of claim 1 (a telecommunications device with capacitive touch sensing), Petitioner introduced Butler, which taught a handheld remote control with a capacitive touch screen for improved user input. Dependent claims 2-4 were argued to be obvious as they recited features also taught by Piepgras, such as using reflective materials (claim 2) and a portable remote (claims 3-4).
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Piepgras and Michael to implement a known wireless communication method (using an antenna, as in Michael) into Piepgras’s remote-controlled lighting system to achieve its intended wireless functionality. A POSITA would have been further motivated to incorporate Butler’s capacitive touch screen to improve the usability of Piepgras’s remote user interface, as touch screens were a well-known and user-friendly technology for portable devices.
  • Expectation of Success: Petitioner asserted that a POSITA would have had a reasonable expectation of success because the combination involved applying conventional components (an antenna and a capacitive touch screen) to known systems (LED lighting and remote controls) to achieve predictable benefits in functionality and user experience.

Ground 2: Obviousness over Piepgras, Michael, Butler, and Naskali - Claim 5 is obvious over Piepgras, Michael, Butler, and Naskali.

• Prior Art Relied Upon: Piepgras (Application # 2003/0137258), Michael (Patent 4,656,398), Butler (Application # 2003/0035075), and Naskali (Patent 7,180,265).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds upon the combination for claims 1-4. Claim 5 adds limitations that the portable telecommunications device (the remote control) comprises an organic LED (OLED) and is configured to receive power wirelessly. Petitioner argued that Piepgras disclosed the use of OLEDs as a known type of LED. The new reference, Naskali, was introduced to teach a system for wirelessly charging portable electronic devices, such as PDAs, using electromagnetic induction.
  • Motivation to Combine: Petitioner argued that since the remote control of the primary combination was portable and battery-powered, a POSITA would be motivated to incorporate Naskali's well-known wireless charging technology for user convenience, eliminating the need for wired charging. Using an OLED for the remote's display was argued to be a simple design choice, leveraging a known high-performance display technology for portable devices.
  • Expectation of Success: Integrating wireless charging was a predictable modification for a portable electronic device, and Naskali explicitly taught its application to devices like PDAs, which Piepgras suggested as a form for its remote interface.

Ground 3: Obviousness over Piepgras, Michael, Butler, and Kasegi - Claim 6 is obvious over Piepgras, Michael, Butler, and Kasegi.

• Prior Art Relied Upon: Piepgras (Application # 2003/0137258), Michael (Patent 4,656,398), Butler (Application # 2003/0035075), and Kasegi (Patent 5,086,294).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground also builds upon the combination for claims 1-4, adding the limitation from claim 6: a current limiting device coupled to the LED circuit. Petitioner introduced Kasegi to supply this element. Kasegi allegedly taught an LED lighting system that used a constant current diode connected in series with an LED to limit the current, thereby protecting the LED and ensuring constant brightness despite voltage fluctuations.
  • Motivation to Combine: A POSITA would have been motivated to add Kasegi’s current limiting device to the LED circuit of the primary combination to improve the system’s reliability and performance. This modification would solve the known problem of LED sensitivity to voltage fluctuations, a common design consideration in LED circuitry.
  • Expectation of Success: Petitioner contended that adding a current limiting device was a standard, well-understood technique in LED circuit design. A POSITA would have had a high expectation of success in implementing this known solution to achieve the predictable result of a more robust and stable lighting product.

• Additional Grounds: Petitioner asserted additional obviousness challenges for claims 21-26 based on combinations including Piepgras, Butler, Naskali, and Zhang, arguing for the obviousness of a lighting device with features such as brightness adjustment circuitry and LED circuits mounted on a reflective printed circuit board.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on the Fintiv factors would be inappropriate. The petition was filed diligently, and the parallel district court litigation was at a very early stage, with no trial date set and minimal investment by the parties or the court. Critically, Petitioner noted there was no overlap between the claims challenged in the inter partes review (IPR) (1-6, 21-26) and the claims asserted in the litigation (7-11). Petitioner further stipulated that it would not pursue in district court any invalidity grounds instituted in this IPR.

5. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-6 and 21-26 of the ’400 patent as unpatentable.