PTAB

IPR2022-00325

Samsung Electronics Co Ltd v. Power2B Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: System for 3D Stylus-Based Display Control
  • Brief Description: The ’369 patent relates to an electronic device with a display and light sensors for determining the three-dimensional (3D) position of a light-emitting stylus. The device controls displayed data and executes functions based on the determined 3D position and movement of the stylus relative to the device's screen.

3. Grounds for Unpatentability

Ground 1: Obviousness over Keely and Geva - Claims 1-9 and 11-16 are obvious over Keely in view of Geva.

  • Prior Art Relied Upon: Keely (Patent 6,337,698) and Geva (GB Application # 2299856).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Keely teaches a pen-based notepad computer with a user interface that facilitates interaction with electronic documents. Keely’s interface responds to pen proximity (i.e., hovering in the air above the screen) to reveal and select tool icons. However, Keely does not specify the mechanism for detecting this 3D position. Geva discloses a position-determining system for pen-based computers that uses arrays of light sensors to detect light from a light-emitting pen. Geva’s system explicitly determines the pen's position in three dimensions (X, Y, and Z), calculating the Z-dimension (distance from the screen) based on the intensity of the detected light. Petitioner contended that combining Keely’s user interface with Geva’s 3D position-sensing technology renders the independent claims obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Geva’s 3D position-sensing technology with Keely’s user interface to provide a specific, effective implementation for the proximity-based features described in Keely. Both references address pen-based computing, making them analogous art. A POSITA would have recognized Geva’s system as an improved, low-power, noise-immune method for determining the pen position needed to enable the user interactions, such as tool selection via hovering, taught by Keely.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. Geva is explicitly designed to work with LCD screens common in notepad computers like Keely’s, making the integration a logical and predictable design choice to enhance the functionality of Keely’s interface.

Ground 2: Obviousness over Keely, Geva, and Kameyama - Claims 10 and 17 are obvious over Keely and Geva, further in view of Kameyama.

  • Prior Art Relied Upon: Keely (Patent 6,337,698), Geva (GB Application # 2299856), and Kameyama (Japanese Application # JPH05-265637).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Keely and Geva to address the additional limitations of claims 10 and 17, which require calculating the angle of the stylus with respect to the screen. Petitioner asserted that the base combination of Keely and Geva teaches all other elements of these claims. Kameyama discloses a "3D Pointing Device" that determines not only the position but also the "posture data" (i.e., orientation or angle) of a light-emitting pen. Kameyama teaches calculating the pen's angle by analyzing the elliptical shape of the light spot projected onto the device’s light-receiving surface.
    • Motivation to Combine: A POSITA seeking to improve the Keely/Geva system would be motivated to incorporate Kameyama's angle-detection technique to capture more sophisticated user input. Determining the stylus's angle allows for more nuanced control and enhanced user interaction, which Keely itself contemplates by considering "the orientation of the pen in the user's hand." Kameyama provides a known and explicit method for calculating this data, making it a natural addition to the combined system.
    • Expectation of Success: A POSITA would have reasonably expected success in adding Kameyama's teachings. Integrating a known method for calculating pen orientation into the processing unit of the Keely/Geva system would be a predictable extension of its capabilities, as all three references operate in the same technical field of 3D input devices for computers.

4. Arguments Regarding Discretionary Denial

  • Arguments against §325(d) Denial: Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was inappropriate. The primary reference, Keely, was never presented to or considered by the examiner during prosecution. While Geva and Kameyama were listed in an Information Disclosure Statement (IDS), they were part of a 40-item list and were not substantively discussed or applied. Petitioner contended that the examiner committed a material error by overlooking the clear teachings of these references, especially when combined with the new primary reference, Keely.
  • Arguments against Fintiv Denial: Petitioner argued that the Fintiv factors strongly weigh against discretionary denial. The parallel district court proceeding was in its earliest stages, with no trial date set, the complaint not yet answered, and no discovery or claim construction underway. Petitioner also filed a stipulation agreeing not to pursue in the district court any invalidity ground that includes the primary reference, Keely, significantly mitigating any overlap of issues. Finally, Petitioner asserted that the strong merits of the unpatentability grounds presented in the petition weigh heavily in favor of institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of Patent 9,946,369 as unpatentable under 35 U.S.C. §103.