PTAB

IPR2024-01077

Samsung Electronics Co Ltd v. Oura Health Oy

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Wearable Ring Computing Device
  • Brief Description: The ’859 patent discloses a wearable ring computing device for monitoring a user's physiological conditions. The device features a housing formed by interior and exterior members that create a waterproof cavity containing a curved battery, a sensor module, and a flexible printed circuit board.

3. Grounds for Unpatentability

Ground 1: Obviousness over Yuen in view of Mestas - Claims 1, 11, and 13-20 are obvious over Yuen in view of Mestas.

  • Prior Art Relied Upon: Yuen (Patent 8,954,135) and Mestas (Application # 2014/0244009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yuen discloses the core elements of a wearable ring computing device, including a "toe band" embodiment with a housing, a cavity, a sensor module, a flexible printed circuit board (PCB), and a processor. Yuen's housing was asserted to have the claimed interior and exterior bounding members. Petitioner contended that Mestas, which teaches a wearable athletic device, supplies the remaining limitations. Specifically, Mestas was argued to teach using a curved battery to conform to a wearable device's form factor, waterproofing the housing cavity to increase durability, and mounting all electronic components (processor, memory) onto the flexible PCB for improved structural integrity and a more compact design. For dependent claims, Yuen was said to disclose the various types of sensors (e.g., heart rate, accelerometer) and a light-emitting diode (LED) as a semiconducting light element. Mestas was used to add wireless charging capabilities and NFC technology for commercial transactions.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Yuen and Mestas because they are analogous arts directed at wearable electronic devices. A POSITA would have been motivated to modify Yuen’s device with Mestas’s teachings to achieve predictable benefits, such as improving user comfort and device durability by using a curved battery, making the device waterproof, and enhancing convenience with wireless charging. These were framed as common design incentives to create a smaller, more robust, and commercially desirable product.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success in combining the references. The electronic components disclosed in both references were described as similar and interchangeable, and their integration would involve routine engineering and well-understood technologies for miniaturizing wearable devices.

Ground 2: Obviousness over Schröder in view of Mestas - Claims 1, 11, and 13-20 are obvious over Schröder in view of Mestas.

  • Prior Art Relied Upon: Schröder (Patent 10,303,867) and Mestas (Application # 2014/0244009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Schröder, as the primary reference, teaches a biometric finger ring that satisfies most claim limitations. Schröder discloses a housing made of two ring halves (interior and exterior bounding members) that create a recess (cavity) to hold a flexible "inlay" (the claimed flexible PCB) with a chip module, sensors, and a battery. Petitioner again relied on Mestas to supply the remaining features. Specifically, Mestas was argued to teach making Schröder’s sealed cavity explicitly "waterproof" using a waterproofing seal, which improves upon Schröder’s general teachings of "plugging" or "gluing" the ring halves. Mestas was also used to teach modifying Schröder’s battery to be curved to better fit the ring's circular shape, thereby allowing for a larger battery without increasing device thickness. For dependent claims, Mestas provided teachings for additional sensors like an accelerometer to supplement Schröder's vein-pattern sensor.
    • Motivation to Combine: Petitioner argued a POSITA would combine Schröder and Mestas as they both relate to wearable biometric sensing devices. A POSITA would have been motivated to incorporate Mestas's features into Schröder's finger ring to enhance its design and functionality. For example, adding Mestas's waterproofing would increase durability, and using Mestas's curved battery would improve the structural design and power capacity of Schröder’s ring. This combination was presented as a predictable integration of known technologies to improve a device.
    • Expectation of Success: Petitioner asserted a high expectation of success because the combination involves applying known improvements (waterproofing, curved batteries) from one wearable device (Mestas) to another (Schröder). As the miniaturization of electronics advanced, implementing Mestas’s teachings into a ring form factor like Schröder's would have been a trivial and predictable modification for a POSITA.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued the Board should not exercise its discretion to deny institution under 35 U.S.C. §314(a) because there is no pending district court litigation involving the ’859 patent against the Petitioner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 11, and 13-20 of the ’859 patent as unpatentable under 35 U.S.C. §103.