PTAB

IPR2022-00502

Samsung Electronics Co Ltd v. Bishop Display Tech LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Surface Light Emitting Apparatus
  • Brief Description: The ’449 patent relates to uniformly illuminating a backlight panel for a laser display using coherent laser beam shaping and refractive optics. The invention purports to improve upon prior art laser backlighting by shaping the laser light intensity to achieve more efficient and uniform illumination.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-4 by Park

  • Prior Art Relied Upon: Park (Application # 2008/0158906).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Park discloses every limitation of claims 1-4. Park’s “back light unit” for a display, which includes a laser light source and a light guide panel, meets the limitations for the claimed “surface light emitting apparatus.” Crucially, Petitioner contended Park’s “holographic diffuser” constitutes the claimed “beam shaping optical element having a refractive aspheric lens.” Park allegedly teaches that this diffuser has “the nature of an aspheric lens” and can be replaced by a micro-lens-array, which a person of ordinary skill in the art (POSITA) would understand is inherently aspherical. Park’s diffuser is also configured to convert the laser beam’s intensity to a more uniform distribution, as required by the claims.

Ground 2: Obviousness of Claims 1-5 over Park in view of Rhodes

  • Prior Art Relied Upon: Park (Application # 2008/0158906) and Rhodes (a 1980 publication titled "Refractive optical systems for irradiance redistribution of collimated radiation").
  • Core Argument for this Ground:
    • Prior Art Mapping: To the extent Park’s holographic diffuser is not found to be a “refractive aspheric lens,” Petitioner argued the combination with Rhodes renders the claims obvious. Park provides the foundational backlight unit, including the laser source and optical guiding section. Rhodes provides a detailed “refractive lens system” with “two aspherical surfaces” specifically designed to convert a Gaussian laser beam into a collimated beam with a uniform intensity profile. The combination would substitute Park’s holographic diffuser with the explicit refractive aspherical lens system taught by Rhodes.
    • Motivation to Combine: A POSITA would combine Park and Rhodes to achieve a more desirable and efficient product. Both references share the common goal of creating uniform illumination from a laser source. Petitioner asserted a POSITA would be motivated to replace Park’s diffuser with Rhodes’s refractive lens system because conventional refractive lenses were cheaper, easier to manufacture, and offered more precise control over beam shaping than the holographic diffusers described in Park.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involves substituting one known optical element (a diffuser) with another known, functionally equivalent optical element (a refractive lens system) to perform its intended and well-understood function of uniformizing a light beam.

Ground 3: Anticipation of Claims 1-3 and 5 by Taniguchi

  • Prior Art Relied Upon: Taniguchi (Japanese Pub. No. JP2004/114065).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Taniguchi discloses all limitations of claims 1-3 and 5. Taniguchi’s “laser irradiation device” anticipates the claimed apparatus. The claimed “beam shaping optical element having a refractive aspheric lens” is met by Taniguchi’s “irradiation distribution conversion element 133,” which explicitly combines two aspherical lenses (31a and 31b) to shape a laser beam. Taniguchi teaches that these aspherical lenses are configured to convert a typical Gaussian laser beam into a beam with a uniform irradiation distribution by diffusing light in the center and collimating it on the sides. For claim 5, which requires a “powered surface,” Petitioner asserted this is inherently met because the refractive aspheric lenses of Taniguchi are a type of powered surface.
  • Additional Grounds: Petitioner asserted additional challenges, including that claims 1-5 are obvious over Park in view of the knowledge of a POSITA, claims 1-5 are obvious over Taniguchi in view of the knowledge of a POSITA, and claim 4 is obvious over Taniguchi in view of Rhodes.

4. Arguments Regarding Discretionary Denial

  • Petitioner presented extensive arguments that discretionary denial under Fintiv would be inappropriate based on a parallel district court litigation. The core arguments were:
    • Uncertain Litigation Schedule: The parallel litigation involves 13 patents across two cases against Petitioner, and the trial date has already been moved once. The complexity and number of co-pending trials scheduled for the same date make it unlikely the current schedule will hold, favoring institution.
    • Early Stage of Litigation: The district court case was in its early stages, with fact discovery not yet complete and no significant investment of resources by the court or parties. Key events like claim construction and expert discovery were still many months away.
    • Lack of Overlap: Petitioner argued the issues would not overlap because it challenged claim 5, which was not asserted in the district court. Furthermore, Petitioner offered a broad stipulation not to pursue in the district court any invalidity ground raised or that could have been reasonably raised using the prior art in this inter partes review (IPR).
    • Strong Merits: Petitioner contended the petition presented strong merits for unpatentability, noting that none of the asserted prior art references were considered during the original prosecution.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-5 of the ’449 patent as unpatentable.