Samsung Electronics Co Ltd v. Slyde Analytics LLC

1. Case Identification

• Case #: IPR2024-00002
• Patent #: 9,651,922
• Filed: October 9, 2023
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Slyde Analytics, LLC
• Challenged Claims: 1-24

2. Patent Overview

• Title: Wristwatch with Touch Screen
• Brief Description: The ’922 patent discloses a wristwatch with a touchscreen interface. The interface displays interactive “cards” (widgets) that a user can navigate by scrolling horizontally or vertically to access different functions.

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 6-19, and 21-24 are obvious over Louch.

• Prior Art Relied Upon: Louch (Application # 2008/0168368).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Louch, standing alone, rendered the majority of the claims obvious. Louch disclosed a digital watch with a touch-sensitive display for presenting and scrolling through widgets. Petitioner contended Louch taught a wristwatch with a digital matrix display (by incorporating Hotelling’s multi-touch LCD) and a touch-sensitive glass overlay (an obvious design choice). Louch’s processor was described as interpreting touch input to scroll through widgets and display a selected widget across the entire screen, meeting the core limitations of independent claims 1, 9, 23, and 24. For example, Louch’s description of scrolling widgets in a “Rolodex® manner” that slowly decelerates to a stop was argued to teach replacing an initial card with a new one without user intervention after the scroll is complete.
  • Motivation to Combine: As a single-reference ground, no motivation to combine was required. Petitioner asserted that all claimed features were either explicitly taught by Louch or would have been obvious modifications to a person of ordinary skill in the art (POSITA).
  • Expectation of Success: A POSITA would have had a high expectation of success as implementing the described user interface features on Louch's digital watch involved predictable and well-established software programming techniques.

Ground 2: Claims 1-13 and 17-24 are obvious over Duarte, Biggs, and Hotelling.

• Prior Art Relied Upon: Duarte (Patent 8,296,684), Biggs (Patent 6,714,486), and Hotelling (Application # 2006/0097991).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted this combination taught every limitation of the challenged claims. Duarte disclosed a user interface for small devices with horizontally and vertically scrollable cards ("windows") that can be displayed in full-screen mode and "snap" into a central position. Biggs disclosed a wristwatch form factor with a touch-sensitive LCD and customizable time displays. Hotelling provided the underlying technology for a multi-point touchscreen with a protective glass layer, capable of performing centroid calculations to determine the center of a touch. Petitioner argued a POSITA would have combined these references to create a wristwatch (Biggs) with an advanced, touch-based scrolling interface (Duarte) implemented using standard touchscreen technology (Hotelling).
  • Motivation to Combine: A POSITA would combine Duarte and Biggs to improve the user interface of Biggs’s watch. Using Duarte’s touchscreen scrolling interface was a more natural and desirable way to navigate through Biggs’s selectable, customized time displays than other input methods. A POSITA would then have turned to a well-known reference like Hotelling to implement the specific hardware for the multi-touch glass screen, as it was a known solution for creating durable touch displays for wearable devices susceptible to bumps and scratches.
  • Expectation of Success: The combination involved applying a known user interface (Duarte) to a known device type (Biggs) using known hardware components (Hotelling). The integration was considered straightforward for a POSITA, leading to a high expectation of success.

Ground 3: Claims 8, 13-17, 21, 22, and 24 are obvious over Louch in view of Duarte.

• Prior Art Relied Upon: Louch (Application # 2008/0168368) and Duarte (Patent 8,296,684).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground built upon Louch as the primary reference and added specific user interface features from Duarte. While Louch taught the basic scrolling of full-screen widgets, Duarte was cited for teaching more advanced transition effects. Specifically, Duarte disclosed scrolling cards in a "closed loop" (the last card returns to the first) and having cards "snap into position" upon completion of scrolling. These teachings were mapped to the limitations of claims 8, 21, 22, and 24 (virtual closed loop) and claims 13 and 17 (scrolling interrupted to align an edge of a card).
  • Motivation to Combine: A POSITA would combine Louch and Duarte to improve the user experience of Louch’s widget-scrolling interface. Adding Duarte’s closed-loop scrolling would provide a quicker navigation mechanism, and the snap-into-place feature would allow a user to center a widget more quickly and precisely than through manual positioning. These were argued to be obvious and desirable enhancements.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in programming the well-understood software logic for closed-loop scrolling and snap-to-center alignment into the existing framework of Louch’s device.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including Louch in view of Hepp (Patent 6,449,219) for simulating a mechanical watch (Claims 5, 20); Louch in view of Park (Application # 2008/0062207) for one-at-a-time card scrolling (Claim 23); and the combination of Duarte, Biggs, and Hotelling in further view of Louch for variable-speed scrolling animations (Claims 14-16).

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) based on the Fintiv factors. Petitioner contended that the district court trial date (February 2025) is scheduled to occur around the same time as the statutory deadline for a Final Written Decision (FWD) in this proceeding (April 2025). Furthermore, Petitioner asserted that investment in the parallel district court case has been minimal, and the strong merits of the petition weigh heavily in favor of institution to simplify issues for trial.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-24 of the ’922 patent as unpatentable.