PTAB

IPR2024-01079

Samsung Electronics Co Ltd v. Oura Health Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wearable Computing Device, Method, and Computer Readable Medium
  • Brief Description: The ’953 patent discloses a wearable computing device in the form of a finger ring. The device uses sensors to detect the motion of a user’s finger or hand, compares the motion to a predetermined pattern, and transmits a signal to an external device upon a match for gesture-based control.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sun - Claims 16-18, 20-21, 23-24, 30-35, and 37 are obvious over Sun.

  • Prior Art Relied Upon: Sun (Application # 2011/0080339).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sun, which discloses a "wrist/finger mouse," teaches all limitations of independent claims 16 and 30. Sun's device is configurable for finger mounting, which Petitioner asserted a person of ordinary skill in the art (POSITA) would understand as a ring form factor. Sun’s device contains a motion sensor (accelerometer, gyroscope), a processor (microcontroller unit), and a transceiver (supporting Wi-Fi, Bluetooth) to acquire gesture data. The processor compares the sensed motion data against stored signatures for memorized gestures (predetermined patterns) and, upon a match, determines a corresponding command (a characteristic of the user's activity) and transmits a signal to an external computer.
    • Motivation to Combine (for §103 grounds): Not applicable as this is a single-reference ground under 35 U.S.C. §103. The argument is that Sun alone renders the claims obvious.
    • Expectation of Success (for §103 grounds): Not applicable.

Ground 2: Obviousness over Sun and Bress - Claims 16-18, 20-21, 23-24, 30-35, and 37 are obvious over Sun in view of Bress.

  • Prior Art Relied Upon: Sun (Application # 2011/0080339) and Bress (Patent 9,218,058).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Sun teaches most claim limitations, as detailed in Ground 1. Bress, which discloses a wearable input device with finger sensors in rings, was argued to provide additional teachings. Specifically, Bress teaches energy management is critical for wireless devices and describes a low-power "sleep" mode where communication channels (transceiver) are shut down. The processor in Bress's device polls motion sensors and activates the transceiver to transmit a data packet only when sensor data matches a pattern, confirming a gesture. This was argued to map directly to the limitation of activating a transceiver in response to a confirmed gesture match.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Sun and Bress because both relate to finger-worn gesture recognition devices. A POSITA would be motivated to implement Bress's specific "sleep" mode functionality in Sun’s device to achieve the recognized and universal benefit of energy savings. Extending battery life is a critical factor for small, wearable devices and provides a strong competitive advantage.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because the references are analogous and involve integrating well-understood technologies, such as power management modes, into a device with standard processors and sensors.

Ground 3: Obviousness over Sun and Asami - Claims 16-18, 20-21, 23-24, 30-35, and 37 are obvious over Sun in view of Asami.

  • Prior Art Relied Upon: Sun (Application # 2011/0080339) and Asami (Application # 2010/0219989).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Sun teaches the core functionality of a gesture-based wearable device. Asami was introduced because it explicitly discloses a wearable input device with its components "provided in a finger ring body." Asami's device uses an acceleration sensor to detect finger motion, calculates a trajectory, and compares it to pre-stored character patterns. Upon a match, the result is sent via a radio transmitter. Petitioner argued Asami's explicit ring form factor and character recognition process supplement Sun's broader disclosure.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Sun and Asami because they are both directed to finger-worn biometric sensing and gesture recognition devices. A POSITA would be motivated to implement the more defined and fashionable finger ring design of Asami with the gesture control system of Sun. Design incentives and market forces would drive a POSITA to create a less bulky, more modern, and versatile alternative to Sun's finger mouse.
    • Expectation of Success (for §103 grounds): There would be a reasonable expectation of success as both devices use similar, interchangeable electronic components (sensors, processors) and are based on routine, predictable technologies for gesture recognition.

  • Additional Grounds: Petitioner asserted additional obviousness challenges over Sun in view of Asami and further in view of Bress (Ground 4), and over Asami in view of Bress (Ground 5), relying on similar motivations to improve power efficiency and form factor.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) and the Fintiv factors. The primary reason provided was that there is no pending district court litigation against Petitioner involving the ’953 patent, making the Fintiv analysis inapplicable.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 16-18, 20-21, 23-24, 30-35, and 37 of the ’953 patent as unpatentable.