Samsung Electronics Co Ltd v. Slyde Analytics LLC

1. Case Identification

• Case #: IPR2024-00041
• Patent #: 10,198,085
• Filed: November 2, 2023
• Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
• Patent Owner(s): Slyde Analytics, LLC
• Challenged Claims: 1-10

2. Patent Overview

• Title: Method and Wristwatch for Switching Power Modes
• Brief Description: The ’085 patent describes a method for a wristwatch to switch from a low-power mode to a higher-power mode. The switch is triggered by using an accelerometer to detect a specific "wristturn" gesture, which is defined by a sequence of orientations and periods of immobility, intended to distinguish intentional user commands from inadvertent movements.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yeung and Ruiz - Claims 1-10 are obvious over Yeung in view of Ruiz.

• Prior Art Relied Upon: Yeung (Application # US 2009/0164219) and Ruiz (Patent 8,228,292).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Yeung disclosed the foundational system: a wrist-worn device with an accelerometer that activates a higher-power function (audio recording) upon detecting a predetermined movement. However, Yeung acknowledged issues with accidental activation. Ruiz taught a solution to this common problem by using a specific, unnatural "double flip" delimiter gesture on a mobile phone to switch operating modes, thereby preventing false positives. The specific steps of the Ruiz gesture—rotating the device away from the user (a first orientation range), then back toward the user (a second, different range), within a predefined time—were alleged to map directly to the limitations of claim 1.
  • Motivation to Combine: A POSITA would combine Ruiz’s robust delimiter gesture with Yeung’s wrist-worn device to solve Yeung's recognized problem of inadvertent mode switching and to conserve power. Applying the unique "double flip" gesture from Ruiz as the "predetermined movement" in Yeung would improve the user experience and reliability.
  • Expectation of Success: Both references used accelerometers in mobile electronic devices for gesture recognition. Petitioner asserted that implementing Ruiz's software-based gesture logic on Yeung's hardware would be a matter of straightforward engineering with predictable results.

Ground 2: Obviousness over Yeung, Alameh, and Joselli - Claims 1-4, 6, and 8-10 are obvious over Yeung in view of Alameh and Joselli.

• Prior Art Relied Upon: Yeung (’219 application), Alameh (Application # US 2011/0148752), and Joselli (a 2010 IEEE article).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground presented an alternative combination to make Yeung's gesture detection more robust. Petitioner asserted Yeung taught the base system of a gesture-activated wristwatch. Alameh taught improving gesture recognition by requiring a device to be held in a "substantially motionless orientation for a preset amount of time" before the main gesture, which served as a cue that a command was forthcoming. This mapped to the "starting position...held within a first range for a defined time" limitation. Joselli taught that intentional gestures have a characteristic duration (e.g., 0.6 to 2 seconds) and that movements outside this window are likely unintentional. This mapped to the limitation requiring the "duration between the starting position and the final position" to be in a "predefined range."
  • Motivation to Combine: A POSITA seeking to improve Yeung’s system would have been motivated to consult Alameh and Joselli to reduce false positives. Alameh’s pre-gesture pause and Joselli’s gesture duration check provided two distinct, known methods for increasing the accuracy of gesture detection, which would directly address Yeung's goal of avoiding accidental activation.
  • Expectation of Success: The references provided compatible, well-understood software-based solutions for the common problem of interpreting accelerometer data. Combining these known filtering techniques was argued to be a predictable design choice for a POSITA.

Ground 3: Obviousness over Yeung-Alameh-Joselli and Yano - Claims 5 and 7 are obvious over the combination of Yeung, Alameh, and Joselli further in view of Yano.

• Prior Art Relied Upon: Yeung (’219 application), Alameh (’752 application), Joselli (a 2010 IEEE article), and Yano (Patent 8,615,375).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination in Ground 2 to specifically address the "50 ms" time limitation recited in dependent claims 5 and 7. While the primary combination taught holding the device in a position for a "defined time," Yano provided the specific motivation for the 50 ms value. Yano taught that to reliably detect a device's state, it is beneficial to average acceleration data over a short, constant time period, and explicitly disclosed that this period "may be 50 milliseconds, for example."
  • Motivation to Combine: When implementing the time-based checks from Alameh and Joselli, a POSITA would have sought a specific, optimal time value. Yano provided a technically justified value of 50 ms for this exact purpose—improving the accuracy of motion detection. A POSITA would have been motivated to incorporate Yano’s teaching to ensure the gesture detection system was reliable.
  • Expectation of Success: Yano’s method of averaging sensor data over a short interval was a known technique for improving signal quality. Applying this specific, disclosed time value to the system of the primary combination was presented as a predictable and successful design choice.

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner argued the ’085 patent was not entitled to its claimed 2011 priority date from its parent Swiss application. The petition asserted that key claim terms and concepts, such as "wristturn" and the method illustrated in Figures 7a-7c, were not disclosed in the Swiss application. Therefore, Petitioner contended the effective priority date is no earlier than October 12, 2012, making references like Ruiz prior art.

5. Arguments Regarding Discretionary Denial

• Fintiv Factors Weigh Against Denial: Petitioner argued that discretionary denial under §314(a) would be inappropriate. The district court trial date in the parallel litigation was set for February 2025, which is after or around the same time as the statutory deadline for a Final Written Decision (FWD) in this inter partes review (IPR). Petitioner contended that because the FWD would issue before trial, and because investment in the district court case has been minimal, the Board's review would simplify issues and promote efficiency, strongly weighing against discretionary denial.

6. Relief Requested

• Petitioner requested institution of an IPR and cancellation of claims 1-10 of the ’085 patent as unpatentable.