PTAB
IPR2025-00147
Samsung Electronics Co Ltd v. Ouraring Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2025-00147
- Patent #: 11,188,124
- Filed: January 23, 2025
- Petitioner(s): Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
- Patent Owner(s): Ouraring Inc.
- Challenged Claims: 1-6, 8-20
2. Patent Overview
- Title: Wearable Computing Device
- Brief Description: The ’124 patent is directed to a wearable computing device configured to be worn around a finger. The device features an external housing with a C-shaped cross section that contains internal components such as a curved rechargeable battery, a printed circuit board (PCB), various sensors, a processor, and a transparent potting material that encapsulates the components.
3. Grounds for Unpatentability
Ground 1: Claims 1-2, 4-5, 8-11, 14, 16, and 18-19 are obvious over Mestas in view of Schröder.
- Prior Art Relied Upon: Mestas (Application # 2014/0244009) and Schröder (Patent 10,303,867).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Mestas taught a wearable athletic device (e.g., wristband) comprising most key elements of the independent claims, including a housing with a C-shaped cross-section, a curved rechargeable battery, a rigid-flex PCB, an accelerometer, a temperature sensor, and a processor. Petitioner asserted Schröder taught a biometric sensing device in a finger-ring form factor, with all electronic components arranged inside, and disclosed using injection molding for manufacturing. The combination of Mestas’s components with Schröder’s finger-ring form factor allegedly rendered the claims obvious.
- Motivation to Combine: A POSITA would combine Mestas’s functionality with Schröder’s compact finger-ring form factor to create a more comfortable device for extended wear, which improves data collection. This modification would also ensure a tighter fit against the skin, reducing motion artifacts and improving sensor reading quality. Such a combination was presented as a predictable design choice driven by universal motivators to make devices smaller and more user-friendly.
- Expectation of Success: Petitioner contended that since both references are in the analogous art of wearable biometric sensors and use standard, interchangeable electronic components, a POSITA would have had a reasonable expectation of success in adapting Mestas's features into Schröder's finger-ring form factor, especially given the known progress in miniaturization.
Ground 2: Claims 3, 6, 12-13, 15, 17, and 20 are obvious over Mestas in view of Schröder and further in view of Yuen.
- Prior Art Relied Upon: Mestas (Application # 2014/0244009), Schröder (Patent 10,303,867), and Yuen (Patent 8,954,135).
- Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the Mestas/Schröder combination by adding Yuen to teach limitations found in specific dependent claims. Petitioner asserted Yuen disclosed a biometric monitoring device with an infrared light source and photodetector arranged on separate rigid portions of a flexible PCB (for claims 3 and 15). Yuen also allegedly taught the use of a thermistor for skin temperature sensing (for claims 6 and 17) and the ability to adjust sensor sampling frequency in response to sensed data to conserve power (for claims 12, 13, and 20).
- Motivation to Combine: A POSITA would incorporate Yuen’s teachings into the Mestas/Schröder finger-ring to enhance its functionality. Specifically, Yuen's optical sensor arrangement would improve sensing efficiency, its thermistor is a well-known component for temperature measurement, and its variable sampling frequency method is a known technique for improving power management in battery-operated wearable devices.
- Expectation of Success: The proposed modifications were argued to be predictable, as Yuen is also in the analogous art. Integrating known sensor configurations and power-saving features from Yuen into the combined Mestas/Schröder device would have been a straightforward implementation for a POSITA.
Ground 3: Claims 1-6 and 8-20 are obvious over Yuen in view of Schröder and further in view of Mestas.
- Prior Art Relied Upon: Yuen (Patent 8,954,135), Schröder (Patent 10,303,867), and Mestas (Application # 2014/0244009).
- Core Argument for this Ground:
- Prior Art Mapping: This ground used Yuen as the primary reference, arguing it taught a wearable biometric device with a C-shaped housing, sensors, a processor, and a transparent encapsulating layer. Schröder was introduced to provide the motivation for adapting Yuen’s device into a more advantageous finger-ring form factor. Mestas was then added for its teachings on a durable rigid-flex PCB, which allows sensitive components to be mounted on rigid sections, and a curved rechargeable battery that conforms to the circular shape of a ring, improving durability and power capacity.
- Motivation to Combine: The motivation was to improve upon Yuen’s device by making it more compact, durable, and suitable for continuous wear. A POSITA would combine Yuen's sensor technology with Schröder's finger-ring form for a better user experience. Adding Mestas’s curved battery and rigid-flex PCB structure would address the practical challenges of fitting components into a small, curved form factor while ensuring structural integrity and maximizing battery life.
- Expectation of Success: Petitioner argued that a POSITA would have reasonably expected success in this combination because all three references relate to the same field. Combining a known form factor (Schröder) with established sensor technology (Yuen) and proven structural and power components (Mestas) represented a predictable convergence of known technologies.
4. Arguments Regarding Discretionary Denial
- Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) based on Fintiv factors. The core reason provided was that there is no pending district court litigation against Petitioner involving the ’124 patent.
5. Relief Requested
- Petitioner requests institution of IPR and cancellation of claims 1-6 and 8-20 of the ’124 patent as unpatentable.
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