PTAB

IPR2023-01410

Hisense USA Corp v. Brightplus Ventures LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Solid-State Luminaires for General Illumination
  • Brief Description: The ’075 patent discloses a lighting panel for general illumination, such as a backlight for an LCD display. The technology involves a substrate with an array of solid-state lighting devices (LEDs), a reflector sheet, a brightness enhancement film (BEF), and a planar diffuser sheet positioned between the reflector and the BEF.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mok, Holman, and Lamb - Claims 1-7 and 9-12 are obvious over Mok in view of Holman and Lamb.

  • Prior Art Relied Upon: Mok (Application # 2006/0227545), Holman (International Publication No. WO 03/056876), and Lamb (Application # 2005/0135115).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mok, the primary reference, disclosed the core elements of independent claim 1: a lighting panel with a substrate, a plurality of LEDs, a reflector, a BEF, and a diffuser sheet arranged between the reflector and BEF. However, Petitioner contended that Mok shows air gaps between its layers. To address this, Petitioner asserted that Holman taught arranging a BEF directly on a reflector sheet without an intervening air gap to create a thinner panel. Petitioner further argued that Lamb explicitly disclosed the functionality of a BEF to preferentially emit light at certain angles and recycle off-angle light to increase brightness and efficiency, mapping to the final limitation of claim 1.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve Mok’s design. Petitioner asserted the motivation was to create a thinner, more uniform, and more efficient lighting panel, which were well-known goals in the art. A POSITA would look to Holman for a thinner stacked arrangement and to Lamb for its teachings on improving brightness and efficiency through light recycling, as all three references are in the same field of LED backlighting.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because combining these known elements—a base panel from Mok, a stacked arrangement from Holman, and enhanced BEF functionality from Lamb—used predictable technologies to achieve a predictable result.

Ground 2: Obviousness over Epstein, Holman, and Lamb - Claims 1-7 and 9-12 are obvious over Epstein in view of Holman and Lamb.

  • Prior Art Relied Upon: Epstein (Application # 2005/0265029), Holman (International Publication No. WO 03/056876), and Lamb (Application # 2005/0135115).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Epstein served as an alternative primary reference, teaching an optical assembly for backlighting with an array of LEDs on a substrate, a reflector layer, a guiding layer that functions as a diffuser, and BEFs. Similar to the argument in Ground 1, Petitioner contended that to the extent Epstein’s layers have air gaps, Holman’s teaching of a stacked BEF-on-reflector arrangement would be used to reduce panel thickness. Likewise, Petitioner argued that Lamb’s explicit disclosure of BEF functionality for light recycling would be incorporated to improve the efficiency of Epstein’s device, thereby teaching all limitations of claim 1.
    • Motivation to Combine: The motivation to combine was presented as nearly identical to that in Ground 1. A POSITA would be motivated to modify Epstein’s backlighting system to incorporate the improvements from Holman (thinner design) and Lamb (higher efficiency). All three references address the common goal of improving LED backlighting systems by managing light output and uniformity, providing a strong rationale for their combination.
    • Expectation of Success: Petitioner maintained that a POSITA would expect success for the same reasons as in Ground 1. The combination involved applying known techniques from analogous prior art to a base system to achieve the predictable benefits of reduced thickness and increased brightness.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. § 314(a) based on Fintiv factors would be inappropriate. The parallel district court litigation was in its early stages, with no trial date set, minimal investment by the parties, and a Final Written Decision (FWD) from the Board would likely issue well before any potential trial. Petitioner also argued that denial under 35 U.S.C. § 325(d) was improper because none of the prior art references relied upon in the petition were previously presented to or considered by the USPTO during the original prosecution of the ’075 patent.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 1-7 and 9-12 of Patent 8,294,075 as unpatentable.