PTAB

IPR2023-00993

Samsung Electronics Co Ltd v. Resonant Systems Inc

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1. Case Identification

2. Patent Overview

  • Title: Linear Vibration Modules and Methods for Operating
  • Brief Description: The ’830 patent discloses linear vibration modules (LVMs) designed to provide vibrational forces in devices like consumer appliances and pagers. The technology focuses on producing vibrations through the linear oscillation of a weight, rather than the unbalanced rotation common in prior art motors.

3. Grounds for Unpatentability

Ground 1A: Claims 1–3, 7–9, 15, 17, and 20 are obvious over Fukumoto.

  • Prior Art Relied Upon: Fukumoto (Patent 7,292,227).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fukumoto, which discloses an electronic device with a linear oscillatory actuator for haptic feedback, teaches all limitations of the challenged claims. Fukumoto’s actuator includes a housing (case 115a), a moveable component (weight 122), a driving component (coil 121), a power supply, and user-input features (touch panel 102). The control component limitation is met by Fukumoto’s CPU and drive signal generation circuit, which generate a drive signal based on waveform data stored in memory to cause oscillation at a specified frequency and amplitude.
    • Key Aspects: For dependent claims, Petitioner asserted Fukumoto teaches using a microprocessor (claim 2), receiving sensor signals to adjust outputs (claim 3), generating magnetic fields parallel to the direction of movement (claim 7), and driving simultaneous oscillation at multiple frequencies to create complex vibration modes (claims 15 and 20).

Ground 1B: Claims 1–3, 7–9, 15, 17, and 20 are obvious over Fukumoto in view of Grant.

  • Prior Art Relied Upon: Fukumoto (Patent 7,292,227) and Grant (Application # 2006/0284849).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that Fukumoto teaches most limitations of claim 1 but argued that if Fukumoto is found not to teach a control component that uses stored values specified by user input, the combination with Grant renders the claims obvious. Grant discloses a system where a user can map haptic effects, including specific amplitudes and frequencies, to events of interest via a user interface, with the mappings compiled into a haptic lookup table (i.e., "stored values").
    • Motivation to Combine: A POSITA would combine Grant's user-programmable haptic codes with Fukumoto’s mobile device to provide user-driven customization of haptic effects. Both references are directed to electromagnetic vibration in mobile devices, and the combination represents the application of a known programming technique (Grant’s lookup table) to a known device (Fukumoto’s actuator) to achieve the predictable result of increased user control.
    • Expectation of Success: The combination required applying known programming steps to a known device, which would predictably increase user control over haptic feedback.

Ground 2A: Claims 1, 2, 7, 11, 15, 17, and 20 are obvious over Ogusu in view of Fukumoto.

  • Prior Art Relied Upon: Ogusu (Japan Patent Application Publication JPH08196053A) and Fukumoto (Patent 7,292,227).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Ogusu, which discloses a moving-magnet vibration actuator for pagers, teaches the core elements of a vibration module. Ogusu’s actuator includes a moveable element (magnets and yokes), a driving component (coils 2b and 3b), and a control section that allows a user to select different vibration waveforms. Fukumoto was added to supply implementation details that Ogusu lacks, such as an explicit housing and a CPU-based control system for generating drive signals from stored waveform data.
    • Motivation to Combine: A POSITA would recognize that Ogusu and Fukumoto are compatible as both relate to linear vibration in mobile devices. A POSITA would be motivated to apply the well-known implementation details from Fukumoto (e.g., a housing for protection, a CPU for control) to Ogusu’s actuator to create a complete and functional device, which would be a predictable application of known techniques.
    • Expectation of Success: Applying Fukumoto’s CPU-controlled generation process to Ogusu’s actuator would predictably result in a pager providing a desired vibration output with a specific amplitude and frequency corresponding to a user input.

  • Additional Grounds: Petitioner asserted numerous other obviousness challenges based on various combinations of the primary art (Fukumoto, Ogusu) with secondary references including Barton (Application # 2006/0248183), Ueda (Application # 2004/0169480), Erixon (Application # 2008/0174187), Fuller (Application # 2008/0001484), Dong (China Patent Application # 101488697A), Saiki (Patent 7,006,641), and Masahiko (Patent 8,917,486) to address limitations related to user-programmable vibration patterns, feedback control, specific actuator configurations, paramagnetic flux paths, and complex waveform generation.

4. Key Claim Construction Positions

  • Petitioner argued that the terms "moveable component," "driving component," and "control component" are non-structural, generic placeholders that invoke means-plus-function (MPF) treatment under 35 U.S.C. §112, ¶6, despite the absence of the word "means."
  • For the "control component," Petitioner identified the corresponding structure in the ’830 patent’s specification as a "Processor and H Bridge Switch" programmed with a specific algorithm to set mode/strength, provide output to a power supply, and provide output to the H-bridge switch based on user input or stored values. This construction was central to mapping the prior art.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate because the factors weigh in favor of institution.
  • Diligence/Investment: The petition was filed early in the co-pending litigation, within eight months of service of the complaint and before claim construction or significant discovery had occurred.
  • Overlap: Petitioner challenged claims (9, 11, 14-16, 19-20) that were not asserted in the district court litigation. Petitioner also stipulated it would not pursue the same grounds or grounds based on the same primary references (Fukumoto and Ogusu) in the district court if the IPR is instituted.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1–9, 11, 14–17, and 19–20 of the ’830 patent as unpatentable.