Samsung Electronics Co Ltd v. Village Green Technologies LLC

1. Case Identification

• Case #: IPR2022-00957
• Patent #: 10,620,663
• Filed: May 31, 2022
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Village Green Technologies, LLC
• Challenged Claims: 1-7, 9-10, 15, 22-31, 34, and 41

2. Patent Overview

• Title: Portable Device with Multiple Displays
• Brief Description: The ’663 patent describes a portable electronic device featuring a primary display and a secondary display. The invention focuses on the interactive functionality between the two displays, where a user's selection on one screen causes related information or an application to appear on the other, and on physical configurations that protect the secondary display when stowed.

3. Grounds for Unpatentability

Ground 1: Anticipation over Liu - Claims 1, 10, 23, and 24 are anticipated by [Liu](https://ai-lab.exparte.com/case/ptab/IPR2022-00957/doc/1004) under 35 U.S.C. §102.

• Prior Art Relied Upon: Liu (Chinese Patent Publication No. CN 1761267A).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Liu, which discloses an improved flip phone, teaches every limitation of the challenged independent claims. Liu’s device has two screens, referred to by Petitioner as a primary display (screen 116 on the body) and a secondary display (screen 122 on the flip cover). Petitioner contended Liu discloses a secondary display that is physically protected when the flip cover is closed and stowed. Critically, Liu describes interactive functionality where selecting an item on the secondary display (e.g., a top-level menu item) causes the primary display to show related information (e.g., a submenu), and vice-versa, meeting the core functional limitations of the claims.
  • Key Aspects: Petitioner asserted that Liu discloses the very combination of interactive, dual-display features that the patent examiner believed was novel during prosecution.

Ground 2: Obviousness over Liu - Claims 1, 2, 10, and 23-25 are obvious over Liu under 35 U.S.C. §103.

• Prior Art Relied Upon: Liu (Chinese Patent Publication No. CN 1761267A).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that to the extent Liu does not explicitly disclose every limitation, any differences would have been obvious modifications. For claim 2, which requires a plurality of operating modes, Petitioner contended it would have been obvious to modify Liu to include: (a) a mode where both displays are off, by implementing a conventional sleep mode to conserve battery; and (b) a mode where only the primary display is on, as it was common for the externally-visible screen on a closed flip phone to remain active to show notifications. When closed, Liu’s secondary display would be stowed and out of sight in both modes.
  • Motivation to Combine (or Modify): A POSITA would modify Liu to improve its functionality and commercial appeal. The motivations included extending battery life (a critical factor for consumers), making the device smaller and easier to transport by ensuring it could be fully closed, and enhancing user convenience with notifications on an external screen—all predictable improvements using known techniques.
  • Expectation of Success: A POSITA would have had a high expectation of success, as implementing features like sleep modes or active external displays were standard practice in the design of conventional flip phones, upon which Liu was an improvement.

Ground 3: Obviousness over Liu in view of Senpuku - Claims 1-7, 9, 10, 15, 22-31, 34, and 41 are obvious over Liu in view of [Senpuku](https://ai-lab.exparte.com/case/ptab/IPR2022-00957/doc/1005).

• Prior Art Relied Upon: Liu (Chinese Patent Publication No. CN 1761267A) and Senpuku (Application # 2005/0083642).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Senpuku, which discloses mobile devices with main and sub-displays in both sliding and hinged configurations, provides teachings that supplement Liu. Senpuku explicitly teaches deploying a secondary display from a stowed, protected position to initiate an operating mode where both displays are active. For example, Senpuku describes pulling out a sub-display to automatically activate it and display details of an email selected on the main display. This addresses claim limitations related to launching an interface software application on the secondary display upon its deployment. For other limitations, Senpuku’s disclosure of a video call function was argued to teach displaying new information (a caller's image) on a secondary display.
  • Motivation to Combine: A POSITA would combine Liu's interactive software features with Senpuku's mechanical deployment and automatic application-launching functionalities. The motivation was to improve user-friendliness and create a more seamless user experience, a stated goal in Senpuku. Combining these known features from similar dual-screen devices was a predictable path to enhancing device usability.
  • Expectation of Success: Success would have been reasonably expected because both references are in the same field of dual-screen mobile devices and address similar problems. Combining a known hinge mechanism from Senpuku with Liu’s device, or implementing Senpuku’s automatic software launch upon deployment, represented the application of known solutions to achieve predictable results.

4. Arguments Regarding Discretionary Denial

• Fintiv Factors: Petitioner argued against discretionary denial under Fintiv, stating that the parallel district court litigation was in its earliest stages, with the complaint not yet served and no trial date scheduled. Petitioner asserted this lack of advancement in the co-pending litigation weighs heavily in favor of institution.
• §325(d) Factors: Petitioner argued that denial under §325(d) would be inappropriate because neither Liu nor Senpuku were before the examiner during the original prosecution. Therefore, the petition raised new arguments and prior art not previously considered by the USPTO.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-7, 9-10, 15, 22-31, 34, and 41 of Patent 10,620,663 as unpatentable.