Zepp Health Corp v. Slyde Analytics LLC

1. Case Identification

• Case #: IPR2024-00833
• Patent #: 8,588,033
• Filed: April 22, 2024
• Petitioner(s): Zepp Health Corp
• Patent Owner(s): Slyde Analytics, LLC
• Challenged Claims: 1-19

2. Patent Overview

• Title: Wristwatch with Simulated Mechanical Movement
• Brief Description: The ’033 patent discloses a wristwatch featuring an electronic display that simulates the movement of a mechanical watch. The simulation includes a visible gear train to replicate the aesthetic appeal of a mechanical watch's inner workings, with the displayed time being synchronized with a quartz oscillator for accuracy.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mooring and Satoshi - 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 taught a wristwatch with a touchscreen LCD, a microcontroller, and a quartz oscillator. Satoshi taught displaying a “skeleton clock” on an LCD, which included an animation of interactive, rotating gears that moved in correspondence with the watch hands to indicate the time. Petitioner asserted that the combination of Mooring’s wristwatch platform with Satoshi’s animated display would teach a microcontroller arranged to reproduce a simulation of a mechanical watch movement with a gear train. Further, the combination would teach synchronizing the time displayed by the simulated movement (from Satoshi) with the more accurate time from the quartz oscillator (from Mooring).
  • Motivation to Combine: A POSITA would combine these references to enhance user interest, a specific motivation cited in Satoshi and acknowledged in the ’033 patent itself. Implementing Satoshi’s visually appealing animated gear display on a modern wristwatch platform like Mooring’s would have been a natural and predictable design choice to meet market demand for watches with the appearance of mechanical movements.
  • Expectation of Success: A POSITA would have an expectation of success because combining the teachings involved well-understood and interchangeable technologies. Both references used standard microprocessors and LCD screens, making the integration of Satoshi’s software-based display onto Mooring’s hardware platform a routine and predictable task.

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 No. 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 by adding Lee, which taught using a touchscreen to directly manipulate and adjust the position of displayed clock hands. Petitioner argued this combination would teach a wristwatch where the electronic display is associated with a touch sensor, and where the position of at least one component of the simulated movement (e.g., a hand or gear) could be modified by pressing or dragging a finger on the display, as claimed.
  • Motivation to Combine: A POSITA would add Lee’s functionality to provide a necessary and intuitive method for a user to adjust the time on the combined Mooring-Satoshi watch. This feature would be needed for common tasks like setting the time after a power loss or changing time zones. The use of a touchscreen for this purpose was a known, user-friendly solution.
  • Expectation of Success: Success would be expected because implementing different user input gestures on microcontroller-based touchscreens was a routine practice 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 No. JP2005/242456), Tam (a 2008 publication on physical-based simulation), and Ruchonnet (Application # 2005/0122844).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner introduced Tam and Ruchonnet to teach the more complex simulations recited in the dependent claims. Ruchonnet disclosed various internal components of a mechanical watch, such as a regulating organ, balance, and oscillating mass. Tam taught the principles of creating physics-based simulations of such components, including calculating the kinetics and dynamics of their movement. Petitioner argued that applying these teachings to the Mooring/Satoshi base would render it obvious to use the accelerometer disclosed in Mooring to measure motion and, in turn, modify the displayed position of simulated components like an oscillating mass or regulating organ based on Tam's simulation principles.
  • Motivation to Combine: The motivation was to create a more realistic and authentic simulation of a mechanical watch. By displaying and simulating the dynamic behavior of internal components in response to the user's actual movements, the combination would significantly enhance the realism and user appeal of the simulated "skeleton" watch.
  • Expectation of Success: A POSITA would expect success in using accelerometer data as an input for a physics-based simulation, as this represented a straightforward application of known sensor technology to improve the fidelity of a graphical simulation.

• Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations incorporating Louch (to teach user-selectable mechanical movements and screen scrolling) and Inoue (to teach crown and push-button controls), relying on similar motivations of enhancing user experience and providing familiar control mechanisms.

4. Key Claim Construction Positions

• Petitioner argued for constructions of two means-plus-function terms under 35 U.S.C. §112(6).
  • For “means for modifying the running of said displayed regulating organ according to the accelerations to which the watch is subjected” (Claim 10), Petitioner identified the corresponding structure as a processor executing a three-step algorithm disclosed in the specification: (1) assigning a virtual mass to the regulating organ, (2) calculating forces on it based on measured accelerations, and (3) displaying its new position.
  • For “means for entering and executing a request for said synchronization by the user” (Claim 12), Petitioner identified the corresponding structure from the specification as “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 exercise its discretion to deny institution under §325(d). The petition contended that the core prior art references, including Mooring, Satoshi, Tam, and Ruchonnet, were not before the examiner during prosecution. It further noted that while Lee was mentioned in the prosecution history, the examiner did not rely on it or provide any substantive analysis of its teachings.

6. Relief Requested

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