PTAB

IPR2023-01385

Hisense USA Corp v. Brightplus Ventures LLC

Key Events

Petition

petition

Title: Apparatus and Methods for Conformable Diffuse Reflectors for Solid State Lighting Devices
Brief Description: The ’812 patent discloses a solid-state lighting device, such as an LED backlight, comprising lighting elements mounted on a substrate referred to as a "tile." The technology centers on a reflector sheet mounted on the substrate that is "configured to conform to a shape of a protruding feature" on the tile's surface.

Prior Art Relied Upon: Chou (Patent 7,497,592).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Chou discloses all elements of the independent claims. Chou describes an LED lighting assembly with a reflector sheet on a circuit board substrate. The key limitation—a reflector sheet "configured to conform to a shape of a protruding feature"—was allegedly met by Chou’s disclosure of a deformable reflector sheet (700) that accommodates protruding features like an LED, its lead, and solder. Chou states the angle of the reflector sheet changes with the dimensions of these components, which Petitioner asserted constitutes conformance.
- Motivation to Combine: This ground is based on a single reference in view of the knowledge of a person of ordinary skill in the art (POSITA). Petitioner asserted a POSITA would recognize that Chou’s teaching of a "deformable material" was a known and obvious alternative to using slits for providing relief, thereby allowing the sheet to conform to surface topography.
- Expectation of Success: A POSITA would have a high expectation of success in using a known deformable reflector material to overlay and conform to the shape of common electronic components on a circuit board.

Prior Art Relied Upon: Chou (Patent 7,497,592) and Starry (Application # 2006/0262310).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Chou provides the base LED backlight assembly, while Starry teaches the specific reflector properties recited in the challenged dependent claims. Starry explicitly discloses a "diffuse reflective article" (claim 2), which comprises a "polymer containing pores" (claim 3). Furthermore, Starry teaches that its reflector is "relatively thin," specifically "less than 250 µm and often less than 150 µm," which satisfies the thickness limitations of claims 4, 5, and 6 (<1.0 mm, <0.50 mm, and <0.25 mm, respectively).
- Motivation to Combine: A POSITA would combine Starry's improved reflector into Chou's similar backlight system for an LCD. Starry provides an express motivation, explaining that diffuse reflectors are critical for maximizing image quality and intensity in LCDs. The motivation to use Starry's thin reflector was driven by the well-known design goal of minimizing the overall thickness of the display.
- Expectation of Success: The combination involved applying a known type of reflector sheet (diffuse, thin, polymer-based) from Starry to the conventional backlight system of Chou to achieve the predictable result of improved optical performance and reduced thickness.

Prior Art Relied Upon: Chou (Patent 7,497,592) and Tabito (Application # 2007/0103908).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Chou provides the foundational backlight assembly, while Tabito provides known solutions for attaching the reflector sheet and other claimed features. Tabito discloses both a mechanical fastening device in the form of "optical stud members" to retain its reflecting plate (claim 7) and chemical bonding using "double-sided adhesive tapes" or an adhesive coating (claims 10-11). Tabito also teaches its reflector can be made of expandable PET, which a POSITA would know is a thermoformable material (claim 19). Both references were asserted to show a single reflector sheet covering multiple tiles (claim 14).
- Motivation to Combine: A POSITA tasked with designing the assembly in Chou would have been motivated to look to known mounting solutions, such as those in Tabito, to secure the reflector sheet. The motivation was to improve the device's structural integrity, durability, and manufacturing reliability, which are simple and predictable design goals.
- Expectation of Success: Applying Tabito's conventional fastening methods (mechanical studs, adhesives) to Chou's assembly would be a straightforward implementation of known techniques to solve a known problem, with a high expectation of success.

Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors is inappropriate. The core reasons provided were that the co-pending district court litigation is in its early stages, with minimal investment by the parties, no trial date set, and the petition was filed promptly after Petitioner received infringement contentions.
Petitioner also argued against denial under §325(d), stating that none of the prior art references asserted in the petition were substantively considered by the examiner during the original prosecution of the ’812 patent.

Petitioner requested the institution of an inter partes review and cancellation of claims 1-7, 10-12, 14-21, and 23 of Patent 7,690,812 as unpatentable.