PTAB

IPR2022-00430

Motorola Mobility LLC v. LuMinTec LLC

Key Events

Petition

petition

Title: Flash Structure for a Handheld Electronic Device
Brief Description: The ’983 patent relates to a flash structure for a portable camera, such as in a mobile phone. The purported invention is the arrangement of a plurality of light-emitting elements (e.g., LEDs) around a camera lens, coupled with a ring-shaped or arc-shaped light diffuser to provide uniform supplemental lighting for photography.

Prior Art Relied Upon: Altek (CN 201269941Y).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Altek, a Chinese utility model, disclosed all elements of the challenged claims. Altek taught a "lens ring structure with a flash lamp arranged around the lens of an electronic product," which could be a mobile phone. This structure included an annular concave reflector with through-holes, a plurality of LEDs projecting through the holes, and a transparent "annular lampshade" that functions as the claimed light diffuser. Petitioner asserted this single reference taught the complete combination of elements recited in independent claims 1 and 9, including the outer cover, baseboard, ring-shaped reflector, LEDs positioned around the lens, and an encircling light diffuser.
- Motivation to Combine (for §103 grounds): As this ground relied on a single reference, Petitioner’s argument focused on Altek inherently teaching all claimed elements, obviating the need for a combination rationale.

Prior Art Relied Upon: Altek (CN 201269941Y) and Sharp (GB 2475705).
Core Argument for this Ground:
- Prior Art Mapping: This ground targeted dependent claims requiring the light diffuser to consist of two or more symmetrical arc-shaped pieces. Petitioner asserted that Altek taught the base flash structure with a single-piece, ring-shaped diffuser ("annular lampshade"). Sharp, which is in the same field of mobile camera flashes, explicitly taught "ring flash" configurations where light guides and diffusers could be formed from a plurality of linear or arc-shaped segments arranged in a circle around the camera module.
- Motivation to Combine (for §103 grounds): Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references to improve Altek’s design. A POSITA would be motivated to replace Altek's single-piece diffuser with Sharp’s segmented diffuser design to achieve predictable benefits, such as providing multiple, distinct lighting points, saving material, and creating additional locations for mechanically coupling the flash components to the device body.
- Expectation of Success: The combination involved substituting a known type of diffuser (segmented) for another (single-piece) in a well-understood application (camera flash). Petitioner contended this would have been a straightforward design choice with a high expectation of success.

Prior Art Relied Upon: Google (Patent 8,743,275) and Altek (CN 201269941Y).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Google disclosed a smartphone with all the key elements of the challenged claims except an explicit annular reflector. Google taught a smartphone with a camera and multiple flash-generating LEDs arranged in a radial array around the camera lens, along with the use of individual light diffusers for the LEDs. Altek was cited for its disclosure of an annular concave reflector with through-holes for LEDs, designed to be placed around a camera lens to direct light.
- Motivation to Combine (for §103 grounds): Petitioner asserted a POSITA would have been motivated to modify Google’s radial LED flash design by incorporating Altek’s annular reflector. The primary motivation was to improve light efficiency and enhance the light output of Google’s flash system. Using a reflector to gather and direct light from an LED source was a well-known and common technique to improve illumination performance.
- Expectation of Success: A POSITA would have had a high expectation of success in adding a known component (Altek's reflector) to Google’s existing flash system to achieve the predictable result of improved brightness and efficiency.

Petitioner argued that discretionary denial under 35 U.S.C. §314(a) and the Fintiv factors was inappropriate. The core arguments were that the parallel district court litigation was in a very early stage with minimal investment from the parties, no substantive orders had been issued, and the trial date was sufficiently distant that a Final Written Decision (FWD) in the IPR proceeding would likely issue before trial, thus promoting efficiency.

Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-15 of the ’983 patent as unpatentable under 35 U.S.C. §103.