MianYang BOE OptoelecTronics Technology Co Ltd v. SamSung DisPlay Co Ltd

1. Case Identification

• Case #: IPR2023-00988
• Patent #: 10,854,683
• Filed: June 21, 2023
• Petitioner(s): Mianyang BOE Optoelectronics Technology Co., Ltd.; Wuhan China Star Optoelectronics Semiconductor Display Technology Co., Ltd.; Tianma Microelectronics Co. Ltd.; and Visionox Technology, Inc.
• Patent Owner(s): Samsung Display Co., Ltd.
• Challenged Claims: 1-2, 4-10, 13, and 15

2. Patent Overview

• Title: Pixel Arrangement Structure for Organic Light Emitting Display Device
• Brief Description: The ’683 patent describes a pixel arrangement for an organic light emitting diode (OLED) display. The invention arranges red, green, and blue pixels along intersecting lines and specifies relative pixel sizes (e.g., green pixels are smallest) to suppress deterioration and improve display lifetime.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-2, 4-10, 13, and 15 over Matthies and Yamada

• Prior Art Relied Upon: Matthies (Patent 6,897,855) and Yamada (Patent 6,366,025).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Matthies teaches an OLED display with red, green, and blue sub-pixels arranged in a repeating, evenly spaced square matrix, which it calls a "quad sub-pixel structure." This structure, with its two green pixels for every one red and blue pixel, inherently discloses the claimed arrangement of first (green), second (blue), and third (red) pixels along intersecting first and second lines passing through their respective centers. While Matthies' layout meets the geometric limitations, it teaches equally sized sub-pixels. Petitioner argued that Yamada supplies the missing sizing limitations by teaching the sizing of OLED pixels based on their differing emission efficiencies to improve display life. Specifically, Yamada teaches making green pixels (highest efficiency) smallest and blue pixels (lowest efficiency) largest.
  • Motivation to Combine: A POSITA would combine Yamada’s sizing solution with Matthies’ pixel layout. Matthies explicitly recognizes that OLED pixels suffer from "aging" and "decay," the exact problem addressed by Yamada. Applying Yamada's well-known technique would be an obvious way to improve the lifetime and simplify the design of Matthies' display by allowing all pixels to be driven with similar currents, representing a predictable improvement.
  • Expectation of Success: A POSITA would have a reasonable expectation of success. The combination involves applying a known design principle (pixel sizing for lifetime) to a compatible system (a standard OLED pixel array) to solve a known problem for the expected benefit of improved display longevity. Matthies itself suggests that adjustments to pixel geometry can be made.

Ground 2: Obviousness of Claims 1, 4-10, 13, and 15 over Phan

• Prior Art Relied Upon: Phan (Patent 7,091,986).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Phan, as a single reference, renders most challenged claims obvious. Phan discloses an OLED display with red, green, and blue dots arranged in a repeating grid pattern, which can form a "square quad pixel" with two green pixels, one red, and one blue. Phan explicitly teaches arranging these dots along horizontal and vertical lines. Petitioner pointed to Phan's Figure 11b, which shows a variation where the central crosspoint is shifted "along a diagonal line," resulting in dots with non-equal areas. In this embodiment, the blue dots are larger and the green dots are smaller, directly mapping to the claimed geometric layout and the relative sizing limitations of the independent claims.
  • Key Aspects: Petitioner contended that since Phan alone teaches a pixel structure meeting the key limitations—including the specific relative sizing that the Patent Owner added to overcome prior art during prosecution—the claims are obvious over Phan without modification.

Ground 3: Obviousness of Claims 1-2, 4-10, 13, and 15 over Murai and Yamada

• Prior Art Relied Upon: Murai (JP 4496852) and Yamada (Patent 6,366,025).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner contended that Murai teaches an OLED display with red, green, and blue dots in a square grid, with the dots arranged to surround a central point. Murai explicitly teaches using corner "cut-offs" of different numbers and sizes to adjust dot areas for improved image quality. In Murai's Figure 3, the green dots have two cut-offs, making them the smallest, while the red and blue dots have none. This satisfies the geometric arrangement and the limitation that the first (green) pixels are smallest.
  • Motivation to Combine: To meet the further claim limitation that blue pixels (second) are larger than red pixels (third), a POSITA would combine Murai's teachings with Yamada. Yamada provides a clear, well-known rule for sizing pixels to improve display life (blue largest, green smallest). A POSITA would apply this principle to Murai’s layout, which already utilizes variable sizing, to gain the additional, known benefit of extended display lifetime without sacrificing the image quality benefits from Murai.
  • Expectation of Success: Because Murai already teaches and enables the re-sizing of its pixels via its cut-off method, a POSITA would have a high expectation of success in applying the specific sizing hierarchy from Yamada to achieve the predictable, combined benefits of improved color (from Murai) and display lifetime (from Yamada).

• Additional Grounds: Petitioner asserted an additional challenge against claim 2 as obvious over Phan in view of Yamada, arguing a POSITA would combine Yamada's full sizing hierarchy with Phan's pixel structure to further improve display life.

4. Arguments Regarding Discretionary Denial

• Denial under §325(d): Petitioner argued that denial would be inappropriate because the primary references relied upon (Matthies, Phan, and Murai) were never considered during prosecution. Although Yamada was cited on the face of the ’683 patent, it was not substantively analyzed or used by the Examiner to reject the claims. Petitioner asserted that the new combinations are substantively different from the art previously considered and overcome the specific deficiencies the Examiner identified during prosecution.
• Denial under §314(a) (Fintiv): Petitioner acknowledged a parallel ITC proceeding involving the ’683 patent but argued this should not trigger discretionary denial. Citing the USPTO's Interim Procedure for Discretionary Denials, Petitioner contended that the pending ITC matter has no bearing on the Board's decision to institute the IPR.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 4-10, 13, and 15 of Patent 10,854,683 as unpatentable.