PTAB

IPR2024-00821

Samsung Electronics Co Ltd v. Broadphone LLC

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Determining a Location for a Portable Device
  • Brief Description: The ’698 patent describes systems for determining if a portable device is at a specific location. The device compares currently measured radio frequency (RF) signal characteristics with a pre-stored "fingerprint" of signal characteristics for a desired location to determine if they match.

3. Grounds for Unpatentability

Ground 1: Obviousness over Spain-I, Hunzinger, and Nanda - Claim 23 is obvious over Spain-I in view of Hunzinger and Nanda.

  • Prior Art Relied Upon: Spain-I (Patent 6,944,465), Hunzinger (Patent 6,957,076), and Nanda (Patent 8,477,731).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Spain-I teaches the core of the claimed invention: a mobile unit that generates and stores signal "fingerprints" (including station IDs and signal strengths) for selected locations and compares a current fingerprint to the stored database to determine its location. However, Petitioner contended Spain-I lacks specifics regarding user-entered locations and detailed comparison logic.
    • To supply these missing elements, Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would look to Hunzinger and Nanda. Hunzinger was cited for its disclosure of a mobile device that allows a user to enter specific locations and program corresponding actions (e.g., reminders) that are triggered when the device determines it has entered or left one of those user-defined locations. This determination is made by comparing current location information (like station IDs and signal strength) with stored information for the user-entered location.
    • Nanda was presented as further evidence that reinforces the obviousness of combining these features. Nanda discloses a system for determining if a device is in the vicinity of a location by comparing a current signal fingerprint (including MAC ID/RSSI) with known fingerprints. Critically, Nanda teaches that a user can initiate the capture of a fingerprint for a new location via a user interface (e.g., a keypad). Nanda also explicitly teaches comparing both station IDs and signal strengths between the current and stored fingerprints.
    • Motivation to Combine: Petitioner argued a POSITA would combine these references to improve the functionality and marketability of the system in Spain-I. Integrating Hunzinger’s user-friendly interface for defining locations of interest and triggering actions would enhance Spain-I’s basic location-matching system, expanding its potential applications to include personalized, location-based services. Nanda provided further motivation by teaching a user-initiated method for building the fingerprint database and detailing a comparison process that uses both station IDs and signal strengths, which would predictably improve the efficiency and accuracy of the location determination process taught by Spain-I. All three references address the same technical problem in the same field.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a reasonable expectation of success in combining these teachings. The integration involved applying conventional user interface technologies and known comparison algorithms (as taught by Hunzinger and Nanda) to the known fingerprinting framework of Spain-I. The combination was a predictable implementation of familiar technologies to yield an improved, but obvious, system.

4. Key Claim Construction Positions

  • "at least one number based on": Petitioner argued that, consistent with statements made during prosecution of the ’698 patent, this term should be understood under its plain meaning to encompass direct signal strength measurements (e.g., a value in dBm) or the output of any simple formula applied to those measurements, such as a difference or average. This interpretation is central to Petitioner's argument that the prior art’s use of direct signal strength values for comparison satisfies this limitation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate under both 35 U.S.C. §325(d) and §314(a) (considering General Plastic and Fintiv factors).
  • §325(d) and General Plastic: Petitioner contended this is not a serial or "follow-on" petition because it challenges claim 23, which was not included in its prior petition (IPR2024-00154). Claim 23 was newly asserted by the Patent Owner in the co-pending district court litigation only after the first IPR petition had been filed. Therefore, the arguments and art are being presented against this claim for the first time.
  • Fintiv Factors: Petitioner argued the Fintiv factors strongly favor institution. The co-pending litigation in the Eastern District of Texas is in its early stages, with a trial date more than 18 months away and significant discovery and claim construction events yet to occur. Petitioner also stipulated that, if the IPR is instituted, it will not pursue the same invalidity grounds in the district court, thus avoiding duplicative efforts and conserving judicial resources. Petitioner further intends to move to consolidate this proceeding with the earlier IPR, which would streamline the process and minimize any impact on Board resources.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 23 of the ’698 patent as unpatentable.