PTAB

IPR2024-01482

Lenovo United States Inc v. Universal Connectivity Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for a Control Bus for Connection of Electronic Devices
  • Brief Description: The ’520 patent relates to a method and apparatus for connecting electronic devices via a control bus. The technology uses a bi-directional, single-line control bus and discloses an arbitration process to manage bus access and prevent data collisions, with data transmission potentially utilizing bi-phase mark encoding.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4, 8-10, 12, 15, 18-19, and 25 are obvious over Yung in view of HDMI 1.3.

  • Prior Art Relied Upon: Yung (Application # 2006/0095596) and HDMI 1.3 (HDMI Specification Version 1.3).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yung, which discloses a system for consumer electronics control based on the HDMI standard, teaches the key limitations of the challenged claims. Yung’s system uses a single, bi-directional Consumer Electronic Control (CEC) bus for transmitting commands between devices, which Petitioner mapped to the claimed "bi-directional, single-line control bus." Petitioner further asserted that Yung’s disclosed arbitration process—where a device checks bus availability, waits for a "signal free time," and then assumes control as an "initiator" while other devices act as "followers"—satisfies the patent’s arbitration and initiator/follower limitations. For the limitation in claim 1(g) requiring a mobile device using a "modified protocol," Petitioner contended that Yung, which implemented older HDMI versions (e.g., 1.0/1.1) as its "standard protocol," expressly teaches applying its system to future protocol versions. A POSITA would combine Yung with the subsequent HDMI 1.3 standard, which introduced the compact HDMI Type-C connector for mobile devices. Petitioner argued this Type-C protocol constitutes a "modified protocol" that was not included in the earlier "standard protocol" used by Yung, thereby rendering the limitation obvious.
    • Motivation to Combine: Petitioner asserted that Yung provides an express motivation to combine its teachings with future HDMI standards. Yung states that its preferred embodiments can be applied in contexts including "future versions of the CEC protocol." Therefore, a POSITA seeking to implement or improve Yung’s HDMI-based system would naturally look to the then-current HDMI 1.3 specification.
    • Expectation of Success: Petitioner argued that applying known techniques from the official HDMI 1.3 standard to a known system explicitly designed around the HDMI framework (Yung) would predictably result in a functional system for digital communication between interconnected audiovisual devices.

Ground 2: Claims 2, 13, and 20 are obvious over Yung in view of HDMI 1.3 in further view of Al-Alawi.

  • Prior Art Relied Upon: Yung (Application # 2006/0095596), HDMI 1.3 (HDMI Specification Version 1.3), and Al-Alawi (Journal of Circuits Systems and Computers, Feb. 2006).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination in Ground 1 to address dependent claims 2, 13, and 20, which require the use of "bi-phase mark encoding." Petitioner argued that the combination of Yung and HDMI 1.3 would be further modified by incorporating the teachings of Al-Alawi. Al-Alawi discloses a communication system controller that explicitly uses Bi-Phase Mark encoding as a robust method for data transmission in multi-protocol environments. Petitioner contended that while Yung's described signaling is flexible and consistent with bi-phase mark encoding, Al-Alawi explicitly teaches the technique in a highly relevant context.
    • Motivation to Combine: Petitioner argued that a POSITA implementing the Yung/HDMI 1.3 system would be motivated to select a specific, advantageous encoding scheme. Yung teaches that the implementation of logical 0s and 1s can be defined by designers, which would prompt a POSITA to investigate known methods. Al-Alawi, which addresses the same technical problem of multi-protocol communication, provides an effective solution. A POSITA would combine Al-Alawi's Bi-Phase Mark encoding to gain its known benefits, such as robust clock recovery and improved error resistance, which are particularly valuable in complex communication systems.
    • Expectation of Success: Petitioner asserted that applying a well-known encoding technique from Al-Alawi to the known communication system of Yung/HDMI 1.3 would be a straightforward integration. A POSITA would have a reasonable expectation of success in achieving a system with predictable, improved signaling performance.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 4, 8-10, 12-13, 15, 18-20, and 25 of the ’520 patent as unpatentable.