PTAB

IPR2024-01222

Samsung Display Co Ltd v. Pictiva Displays Intl Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of Encapsulating an Organic Light Emitting Device and an Organic Light Emitting Device
  • Brief Description: The ’389 patent discloses methods for encapsulating organic light emitting diode (OLED) devices to protect them from environmental damage, primarily from oxygen and moisture. The invention describes a "direct thin-film encapsulation" method involving selectively depositing alternating organic planarization layers and inorganic barrier layers over the OLED devices.

3. Grounds for Unpatentability

Ground 1: Claims 34, 35, 37, and 40 are obvious over Yamazaki in view of Ghosh and Applicant Admitted Prior Art (AAPA)

  • Prior Art Relied Upon: Yamazaki (Application # 2003/0206332) and Ghosh (Application # 2001/0052752).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yamazaki taught a method of encapsulating a single OLED device by selectively depositing a planarizing organic "cover layer" and an inorganic "barrier layer." However, Yamazaki did not explicitly disclose applying this method to a plurality of devices in a batch fabrication process. Petitioner asserted that Ghosh and the AAPA in the ’389 patent itself remedy this by explicitly teaching the batch fabrication of a plurality of OLED devices on a single large substrate to improve efficiency and reduce cost. The combination of Yamazaki's selective deposition method with Ghosh's batch fabrication process allegedly rendered the method of independent claim 34 obvious. Dependent claims 35, 37, and 40 were allegedly met as Yamazaki taught using ink jet deposition (claim 35), a shadow mask (claim 37), and sputtering or shadow masking for the barrier layer (claim 40).
    • Motivation to Combine: A POSITA would combine Yamazaki's encapsulation method with the batch fabrication process taught by Ghosh and the AAPA because batch fabrication was the conventional, cost-effective mode for manufacturing flat-panel displays. Applying Yamazaki’s specific layering technique to this standard manufacturing process was a predictable combination to gain the benefits of both technologies.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references were directed to thin-film encapsulation of OLED devices. The ’389 patent admitted it was conventional to use batch fabrication for such devices, confirming that applying Yamazaki's layering method in a batch context would be straightforward.

Ground 2: Claims 41-46 are obvious over Yamazaki in view of Ghosh/AAPA and Fujimori

  • Prior Art Relied Upon: Yamazaki (Application # 2003/0206332), Ghosh (Application # 2001/0052752), and Fujimori (Japanese Published Application No. H10-41069).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Yamazaki/Ghosh combination from Ground 1 to address the mask-specific limitations of independent claim 41. Petitioner contended that while Yamazaki taught using a mask for selective deposition, Fujimori provided the specific teachings for a "mask attached to a substrate with magnetic force." This modification allegedly met the limitations of depositing a mask on the substrate with openings over the devices (claim 41), using a magnetically held mask (claim 42), ensuring the mask is in contact with the substrate (claim 43), using non-sticking materials (claim 44), and comprising metal or polymer (claim 45).
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to incorporate Fujimori's magnetic mask into Yamazaki's process to achieve better deposition control and accuracy, an explicit objective of Yamazaki. Fujimori's technique was designed to solve common problems with conventional masks, such as warping and poor adhesion, which would improve the precision of Yamazaki’s selective deposition process.
    • Expectation of Success: The combination involved applying a known masking technique (Fujimori) to a known encapsulation method (Yamazaki) to achieve a predictable improvement in precision. Both references contemplated using masks for patterning layers in OLED fabrication, ensuring a high expectation of success.

Ground 3: Claims 34 and 40 are obvious over Weaver

  • Prior Art Relied Upon: Weaver (Application # 2002/0140347).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Weaver, as a single reference, taught all elements of claim 34. Weaver disclosed encapsulating an OLED device with a protective structure comprising an alternating series of organic "planarizing layers" and inorganic "high-density layers" (acting as barrier layers). Critically, Weaver taught that these layers were deposited selectively over the device and explicitly suggested its method was advantageous for encapsulating a plurality of devices on large sheets of material that are subsequently subdivided, thus teaching the entire claimed method. Weaver also taught that its high-density barrier layers could be applied by techniques including thermal evaporation and sputtering, meeting the limitations of claim 40.
    • Motivation to Combine (N/A): This ground was based on a single reference.
    • Expectation of Success (N/A): This ground was based on a single reference.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 35 and 36 are obvious over Weaver in view of Palanisamy (Application # 2003/0011300), and claim 37 is obvious over Weaver in view of Burrows (Patent 6,866,901), which introduced known selective deposition techniques (ink jet, screen printing, shadow mask) into Weaver's framework.

4. Key Claim Construction Positions

  • "depositing by shadow mask, sputtering, ink jet deposition, screen printing [or] evaporation" (Claim 40): Petitioner argued that based on the file history, this phrase should be interpreted to include an "or" conjunction. The original claim included a group of deposition methods, and an Examiner's amendment that removed grouping language intended for the options to be read disjunctively.
  • "non-sucking to OLED substrate" (Claim 44): Petitioner contended this phrase in the issued patent was a typographical error. The claim as prosecuted used the term "non-sticking." Petitioner argued the claim should be interpreted as requiring a "non-sticking" material, which is a known property for removable deposition masks.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The petition was filed in response to litigation in the Eastern District of Texas that was in a "very early stage." Key milestones, such as claim construction and depositions, had not yet occurred, and the trial was scheduled for August 2025. Petitioner asserted it had acted with diligence and that the IPR presented compelling evidence of unpatentability that would promote administrative efficiency.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 34-37 and 40-46 of the ’389 patent as unpatentable.