Garmin Ltd v. Slyde Analytics LLC

1. Case Identification

• Case #: IPR2024-00765
• Patent #: 8,588,033
• Filed: April 22, 2024
• Petitioner(s): Garmin Ltd.
• Patent Owner(s): Slyde Analytics, LLC
• Challenged Claims: 1-19

2. Patent Overview

• Title: Simulating Mechanical Watch Movement
• Brief Description: The ’033 patent discloses a wristwatch with an electronic display that simulates the appearance and movement of a traditional mechanical watch. The invention aims to appeal to users who appreciate the aesthetics of mechanical watch workings, such as visible gear trains, by reproducing them on a modern electronic device.

3. Grounds for Unpatentability

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

• Prior Art Relied Upon: Mooring (Application # 2009/0196124) and Satoshi (Japanese Publication # JP2005/242456).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Mooring taught a modern wristwatch with the necessary hardware, including a watchcase, an LCD touchscreen, a microprocessor, and a quartz oscillator for accurate timekeeping. However, Mooring only disclosed a standard analog or digital time display. Satoshi taught the specific software-based concept of simulating a "skeleton clock" on an LCD, including an animation of rotating gears that correspond to the movement of watch hands to indicate time. The combination of Mooring’s hardware and Satoshi’s software simulation met the limitations of independent claim 1.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to satisfy a known market demand for watches that display their inner workings, thereby enhancing user interest. Applying Satoshi's visually appealing simulation to Mooring's capable hardware platform was presented as a predictable design choice.
  • Expectation of Success: Success was predictable because both references relied on conventional, well-understood technologies like microprocessors and LCD screens, making the integration of Satoshi’s software onto Mooring’s hardware straightforward.

Ground 2: Obviousness over Mooring, Satoshi, and Lee - 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 # JP2005/242456), and Lee (Application # 2008/0186808).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the base combination of Mooring and Satoshi. Petitioner asserted that Lee addressed the limitations of claims 2, 3, and 17 by teaching the use of a touchscreen to directly adjust the displayed time. Specifically, Lee disclosed detecting a user’s finger press on a clock hand (e.g., the hour or minute hand) and dragging it to a new position to set the time. This taught modifying the position of a movement component via a touch sensor.
  • Motivation to Combine: A POSITA would incorporate Lee’s teachings to provide a necessary and intuitive method for users to set or adjust the time on the combined Mooring/Satoshi watch. A watch, even a simulated one, requires a means for time adjustment, and using the existing touchscreen for this function was a logical improvement.
  • Expectation of Success: Implementing touch-based time adjustment as taught by Lee on the Mooring watch, which already included a touchscreen, was a routine and predictable task for a POSITA.

Ground 3: Obviousness over Mooring, Satoshi, Tam, and Ruchonnet - 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 # JP2005/242456), Tam (a 2007 technical paper on physical-based watch simulation), and Ruchonnet (Application # 2005/0122844).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed claims related to more realistic, physics-based simulations using sensor data. Ruchonnet disclosed the detailed internal components of a real mechanical watch, including a regulating organ, balance, escapement, and oscillating mass. Tam taught how to create a "physical-based simulation" of such components by calculating the forces, kinetics, and dynamics that govern their movement. Petitioner argued that the combination of these references taught modifying the simulated watch components based on real-world forces.
  • Motivation to Combine: A POSITA would combine these references to create a more authentic and dynamic simulation of a mechanical watch, further enhancing user interest. Specifically, a POSITA would use the accelerometer already disclosed in Mooring to measure real-time motion and provide that data as an input to the physics-based simulation taught by Tam, thereby causing the simulated internal components from Ruchonnet to react realistically to the user's movements.
  • Expectation of Success: Combining these teachings was predictable, as it involved applying known physics simulation techniques (Tam) to known mechanical components (Ruchonnet) using data from a standard sensor (the accelerometer in Mooring).

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations with Louch (Application # 2008/0168368) for scrolling user interfaces and with Inoue (Application # 2008/0151700) for using a physical crown and push-buttons to control the simulated watch.

4. Key Claim Construction Positions

• Petitioner argued that two terms in dependent claims should be construed under 35 U.S.C. §112(6) as means-plus-function limitations.
• "means for modifying the running of said displayed regulating organ according to the accelerations to which the watch is subjected" (Claim 10): Petitioner asserted the recited function is modifying the organ's display based on acceleration. The corresponding structure was identified as the three-step algorithm disclosed in the ’033 patent: (1) assigning a virtual mass, (2) calculating forces from measured accelerations, and (3) displaying the new position.
• "means for entering and executing a request for said synchronization by the user" (Claim 12): Petitioner asserted the recited function is user-initiated time synchronization. The corresponding structure was identified as "one of the push-buttons 41 or the touch sensor" as disclosed in the patent.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise discretionary denial under Fintiv. The petition contended that the parallel district court litigation was in a "pre-infancy stage," having been filed less than a month before the IPR petition. Service on the Petitioner, a foreign entity, had not occurred and was expected to take several months. Consequently, no trial date was set, and it was argued to be highly unlikely that a trial would occur before the Final Written Decision in this IPR proceeding.

6. Relief Requested

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