PTAB

IPR2024-01425

Aputure Imaging Industries Co Ltd v. Rotolight Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Lighting System
  • Brief Description: The ’258 patent discloses a lighting system comprising an integrated lighting device and a controller. The controller is adapted to produce a range of user-customizable cinematic lighting special effects by using an "effect simulator" to calculate a time-varying lighting value based on user-selected parameters and output it to the lighting device.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 and 8-22 are obvious over Mueller.

  • Prior Art Relied Upon: Mueller (Application # 2005/0275626).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mueller, which discloses an "Entertainment Lighting System," teaches every element of the challenged claims. Mueller describes a lighting unit containing a processor (the controller) and an interface for receiving user signals to select and customize various pre-programmed, time-varying lighting effects such as a "rainbow chase," fires, and explosions. The processor is configured to calculate and provide control signals to light sources to generate these dynamic, multi-color effects based on user-selectable parameters (e.g., timing, intensity, hue). Petitioner asserted that Mueller’s lighting unit, which contains both light sources and a processor, meets the limitation of an integrated lighting device and controller.
    • Key Aspects: This ground asserts that a single prior art reference discloses all claimed features, framing the invention as a collection of long-known aspects of cinematic and videographic lighting systems.

Ground 2: Claims 1-6 and 8-22 are obvious over Showline in view of Mueller.

  • Prior Art Relied Upon: Showline (Installation & User’s Manual for Showline SL PAR 155 ZOOM RGBW LED Luminaire), Mueller (Application # 2005/0275626).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended Showline, a user manual for a commercially available RGBW LED luminaire, discloses a physical embodiment of the claimed system. Showline describes an integrated unit with a high-intensity LED array (lighting device) and an LCD Display/Menu System (controller) that allows users to select, customize, store, and recall various lighting effects like "presets" and "chases." The manual details how users can adjust parameters such as master intensity, color values, speed, and fade for these effects. While Showline describes the system's functionality from a user perspective, it lacks technical details on the internal processor and software implementation. Mueller was argued to supply these missing technical details, disclosing the necessary processor, memory, and algorithms to calculate time-varying lighting values based on user-selected parameters.
    • Motivation to Combine: A POSITA interested in designing a system like the one described in the Showline manual would be motivated to consult technical references like Mueller to learn the internal workings and implementation details for the controller’s processor and software.
    • Expectation of Success: A POSITA would have a high expectation of success in combining the teachings, as it would involve implementing the known functionality of the Showline product using the conventional processor and software design principles disclosed in Mueller.

  • Additional Grounds: Petitioner asserted two additional obviousness grounds specifically targeting claim 7, which requires at least one "warm" white and one "cool" white LED. These grounds add Choong (Patent 8,632,208) to the primary combinations (Mueller in view of Choong, and Showline in view of Mueller and Choong). Choong was cited to demonstrate that using a combination of warm and cool white LEDs to produce a broad spectrum of color temperatures was a well-known and obvious technique to a POSITA.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) or §314(a) is not warranted. The petition asserted that the prior art combinations presented are new and were not considered during prosecution.
  • Regarding the General Plastic factors, Petitioner argued that denial is inappropriate because it has not previously filed a petition challenging the ’258 patent and has no significant relationship with any prior petitioners.
  • Regarding the Fintiv factors for co-pending district court litigation, Petitioner argued against denial because the litigation is in its very early stages, no trial date has been set, minimal investment has occurred, and the average time to trial in the relevant jurisdictions is significantly longer than the timeline for a Final Written Decision in an IPR.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-22 of the ’258 patent as unpatentable under 35 U.S.C. §103.