PTAB

IPR2022-00874

Samsung Electronics Co Ltd v. Aire Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Communication Apparatus for Setting Up a Data Connection Between Intelligent Devices
  • Brief Description: The ’360 patent describes a communication apparatus for automatically establishing a data connection between intelligent devices in close proximity. The technology, similar to Near Field Communication (NFC), uses inductively linked coils and involves one device emitting search signals until a response is received from another, enabling data exchange.

3. Grounds for Unpatentability

Ground 1: Obviousness over Naruse and Nishikawa - Claim 1 is obvious over Naruse in view of Nishikawa.

  • Prior Art Relied Upon: Naruse (JP Patent Pub. No. 2001/243431) and Nishikawa (JP Patent Pub. No. 2001/283162).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Naruse discloses an intelligent device with a low-power standby state that meets most limitations of claim 1. Naruse’s device includes a transmission oscillator with a coil, a "noncontact sensor circuit" (measuring device) that detects a change in the oscillator’s frequency when another device is near, and a "controlling circuit" (switching apparatus). Upon detecting a change, the sensor sends an interrupt signal to the controlling circuit, which then connects the communication element to a power supply to exit the standby state.
    • Motivation to Combine: A POSITA would combine Nishikawa with Naruse to supply details on how communication sessions are initiated, which Naruse lacks. Nishikawa teaches the well-known technique of emitting a "search signal" and receiving a "response signal" to establish a connection. This modification would allow Naruse’s device to communicate with multiple types of devices and conform to standards like ISO 14443, increasing its utility.
    • Expectation of Success: Petitioner asserted success was expected because applying Nishikawa's known search/response technique to Naruse's similar contactless communication system would predictably enhance its functionality without altering its core operation.

Ground 2: Obviousness over Naruse, Nishikawa, and Cole - Claims 2-7 and 17 are obvious over Naruse in view of Nishikawa and Cole.

  • Prior Art Relied Upon: Naruse, Nishikawa, and Cole (Patent 6,144,299).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Cole to the base combination to address dependent claims related to modifying oscillator properties. Cole was cited for its teachings on switching an assembly into a tuned circuit to alter its characteristics for data communication. Specifically, Cole’s data communications microcircuit uses a transmission gate to switch capacitors and resistors into the circuit, which causes an increase in bandwidth (claims 2, 3) and a change in resonant frequency (claims 4, 5, 6, 17). Cole also discloses sweeping the measuring frequency over a predetermined range to detect a device’s presence (claim 7).
    • Motivation to Combine: A POSITA would incorporate Cole's teachings to provide a specific, effective implementation for data communication that is not detailed in Naruse. Cole’s methods for modifying circuit properties would improve communication fidelity and align with Naruse's goal of low power consumption. Additionally, applying Cole’s frequency sweeping technique would make the proximity detection in the Naruse/Nishikawa system more robust and reliable.
    • Expectation of Success: Petitioner argued success was expected because the combination involved applying known circuit modification and detection techniques from Cole to a similar contactless system to achieve predictable improvements in communication performance and detection capability.

Ground 3: Obviousness over Naruse, Nishikawa, and Rodenbeck - Claims 8-9 are obvious over Naruse in view of Nishikawa and Rodenbeck.

  • Prior Art Relied Upon: Naruse, Nishikawa, and Rodenbeck (Patent 6,535,136).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Rodenbeck to the base combination to address claims directed to power-saving functionality. Rodenbeck teaches a wake-up circuit for a proximity card reader that cyclically switches its measuring device on and off to minimize power consumption (claim 8). Rodenbeck’s software-controlled system explicitly keeps the "on" state for detection (e.g., 50 microseconds) significantly shorter than the "off" low-power state (e.g., 250 milliseconds), directly teaching the limitation of claim 9.
    • Motivation to Combine: A POSITA would be motivated to combine Rodenbeck to further Naruse's stated goal of reducing power consumption and extending battery life. Rodenbeck’s cyclical power-down technique provides a clear, proven method to achieve additional power savings beyond those already implemented in Naruse’s standby mode, making it an attractive and logical improvement.
    • Expectation of Success: Petitioner contended that applying Rodenbeck's power-saving strategy was a straightforward application of a known technique to an analogous device. The outcome—reduced power usage without hindering proximity detection functionality—was predictable.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Plonsky (Patent 5,049,857) for its teachings on storing and averaging measured values for comparison against a baseline (claims 10-12), and Clark (EP Patent Pub. No. 0 052 933 B1) for its teachings on using phase relationships between two oscillators for detection (claims 13-14). Petitioner also asserted that claim 15 is anticipated by Naruse and claim 16 is obvious over Naruse and Cole.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The parallel district court litigation is in its infancy with minimal investment from the court and parties. The scheduled trial date is only about three months before the Final Written Decision deadline, minimizing efficiency concerns. Furthermore, Petitioner stipulated that it would not pursue in the district court any invalidity grounds raised in the IPR if review is instituted, thereby eliminating overlap. Petitioner also asserted that the strong merits of 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 the ’360 patent as unpatentable.