Samsung Electronics Co Ltd v. Slyde Analytics LLC

1. Case Identification

• Case #: IPR2024-00006
• Patent #: 8,588,033
• Filed: October 16, 2023
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Slyde Analytics, LLC
• Challenged Claims: 1-19

2. Patent Overview

• Title: Simulating a mechanical watch movement
• Brief Description: The ’033 patent discloses a wristwatch with an electronic display that reproduces a simulation of a mechanical watch movement, including a gear train, to indicate the time. The invention is based on the premise that users appreciate the aesthetic of mechanical watches, including their visible inner workings.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 11-14 are obvious over Mooring in view of Satoshi.

• Prior Art Relied Upon: Mooring (Application # 2009/0196124) and Satoshi (Japanese Publication No. JP2005/242456).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Mooring disclosed the foundational elements of independent claim 1, including a wristwatch with a watchcase, an electronic display, a quartz oscillator, and a microcontroller. Petitioner contended that Satoshi taught the missing element: simulating a mechanical "skeleton clock" movement with a visible, rotating gear train on an electronic display to indicate time. For dependent claims, Petitioner asserted that Satoshi’s disclosure of user-requested synchronization taught the manual synchronization of claim 12, and that performing this periodically for accuracy would be an obvious modification for claim 11.
  • Motivation to Combine: A POSITA would combine these references to enhance user interest. The ’033 patent itself admitted it was known that users enjoy the appearance of mechanical movements. A POSITA would have been motivated to apply Satoshi's visually appealing "skeleton clock" simulation to Mooring's capable wristwatch platform to satisfy this known market demand.
  • Expectation of Success: Petitioner asserted a high expectation of success because both references involved displaying time on standard LCD screens controlled by microprocessors, making the integration a predictable combination of known technologies.

Ground 2: Claims 2-3, 17, and 19 are obvious over Mooring and Satoshi in further view of Lee.

• Prior Art Relied Upon: Mooring (Application # 2009/0196124), Satoshi (Japanese Publication No. JP2005/242456), and Lee (Application # 2008/0186808).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Mooring/Satoshi combination by adding Lee. Petitioner argued that Lee explicitly taught using a touchscreen to modify the position of displayed watch hands, directly mapping to the limitations of claims 2, 3, and 17. Lee disclosed a user touching and dragging hour or minute hands to a desired location on the screen. Petitioner asserted that because Satoshi’s hands and gears were linked, modifying the hand position as taught by Lee would necessarily modify the angular position of the gear train elements.
  • Motivation to Combine: A POSITA would add Lee's teachings to provide an intuitive and necessary method for time adjustment on the Mooring/Satoshi touchscreen watch. A user would need a way to set the time, such as after a battery change or when changing time zones, and using the existing touchscreen for this function would be a logical and obvious improvement.
  • Expectation of Success: Success would have been expected because implementing touch-based controls for on-screen elements was a routine and well-understood practice for a POSITA at the time.

Ground 3: Claims 6-10 and 13 are obvious over Mooring and Satoshi in further view of Tam and Ruchonnet.

• Prior Art Relied Upon: Mooring (Application # 2009/0196124), Satoshi (Japanese Publication No. JP2005/242456), Tam (a 2008 publication on physical-based simulation), and Ruchonnet (Application # 2005/0122844).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground added Tam and Ruchonnet to address claims related to more realistic, physics-based simulations responsive to external forces. Petitioner argued that Mooring disclosed the required accelerometer. Ruchonnet disclosed various internal mechanical watch components, such as a regulating organ, balance, and oscillating mass. Tam taught the physics-based simulation of such internal components, including calculating forces (kinetics and dynamics) to determine their movement and position. Petitioner contended that combining these would result in a simulation where data from Mooring's accelerometer is used to calculate forces and modify the position of simulated internal components (from Ruchonnet) using the simulation methods of Tam. This combination directly mapped to claims 6-10.
  • Motivation to Combine: The motivation was to create a more realistic and dynamic simulation to further enhance user interest. A POSITA seeking to improve upon the static simulation of Mooring/Satoshi would have looked to prior art like Tam and Ruchonnet to simulate how a real mechanical watch reacts to movement, thereby making the virtual watch more authentic.
  • Expectation of Success: Petitioner argued success was predictable, as it involved applying known physics simulation techniques (Tam) to known watch components (Ruchonnet) using data from a standard sensor (Mooring's accelerometer), all implemented in software.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds based on combinations of Mooring, Satoshi, and Louch (for scrollable user interfaces); Mooring, Satoshi, Inoue, and Tam (for crown/push-button simulation); and a final ground combining all six references for claim 18.

4. Key Claim Construction Positions

• "means for modifying the running of said displayed regulating organ according to the accelerations to which the watch is subjected" (Claim 10): Petitioner argued this is a means-plus-function term under 35 U.S.C. §112(6). The function is modifying the regulating organ's displayed running based on accelerations. The corresponding structure is a processor executing the three-step algorithm disclosed in the specification: (1) assigning a virtual mass to the organ; (2) calculating forces based on measured acceleration; and (3) displaying the organ's new position.
• "means for entering and executing a request for said synchronization by the user" (Claim 12): Petitioner argued this is a means-plus-function term. The function is user-initiated synchronization. The corresponding structure disclosed in the specification is "one of the push-buttons 41" or "the touch sensor," or their equivalents.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not issue a discretionary denial under Fintiv. The petition asserted that the district court trial date (February 2025) is scheduled around the same time as or after the statutory deadline for a Final Written Decision (FWD) (approx. April 2025), weighing against denial. Furthermore, Petitioner contended that because the petition was filed early in the co-pending litigation—before significant investment by the court or parties—and because the petition's merits are exceptionally strong, the Fintiv factors holistically weigh strongly against discretionary denial.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’033 patent as unpatentable.