PTAB

IPR2025-00331

Samsung Electronics Co Ltd v. Sinotechnix LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Irradiance-Redistribution Illumination Lens
  • Brief Description: The ’162 patent discloses a lens designed to convert non-uniform light from a compact source, such as an LED, into an output beam with a uniform light distribution. The lens comprises specific concave entry and exit surfaces mathematically designed to redistribute the light intensity.

3. Grounds for Unpatentability

Ground I: Obviousness over Tawa and Shikama - Claims 1, 4-6, 8, 31, 39, and 43 are obvious over Tawa in view of Shikama.

  • Prior Art Relied Upon: Tawa (Patent 6,356,395) and Shikama (Patent 5,384,659).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tawa disclosed a "light intensity distribution converting device" that functions as a collimator lens to convert non-uniform Gaussian light into a uniform output beam, teaching most limitations of the challenged claims. Tawa’s device used mathematically calculated entry and exit surfaces to achieve this redistribution. However, the ’162 patent’s independent claims require both the entry and exit surfaces to have a specific concavity, with the exit surface’s concavity being "substantially greater" than the entry surface’s. Petitioner asserted that Tawa’s primary embodiment showed a concave entry surface but a convex exit surface. To address this, Petitioner contended a POSITA would have looked to Shikama, which taught a condenser lens with complex aspherical surfaces. Shikama explicitly taught a lens where the curvature of one surface (S1) is significantly greater than the other (S2), providing a known design for achieving specific optical properties with varying curvatures.
    • Motivation to Combine: Petitioner argued a POSITA would combine Tawa’s method for achieving uniform illumination with Shikama’s known lens shapes to obtain a predictable result. The combination represented a simple application of a known lens design principle (from Shikama) to improve or modify a known device (Tawa's lens) to achieve the desired optical output. A POSITA would have been motivated to explore different lens curvatures, as taught by Shikama, to optimize the performance of Tawa's light-redistributing lens.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the modification involved applying routine optical calculations, the very method taught by Tawa, to implement a different but well-understood lens profile taught by Shikama. The result—a lens with different curvatures that still produced uniform light—was predictable.

Ground II: Obviousness over Tawa, Shikama, and Scharf - Claim 9 is obvious over Tawa and Shikama in view of Scharf.

  • Prior Art Relied Upon: Tawa (Patent 6,356,395), Shikama (Patent 5,384,659), and Scharf (Patent 6,105,869).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted this ground builds upon Ground I, with the combination of Tawa and Shikama teaching the lens of claim 8 (a lens for an LED source). Dependent claim 9 further requires "multiple lenses... laterally arrayed... above multiple light sources... in association with a common circuit board." Petitioner argued Tawa’s Figure 20 disclosed an array of its lenses over a corresponding array of LEDs. However, Tawa did not explicitly teach mounting the LEDs on a common circuit board. Scharf was introduced to supply this limitation, as it expressly taught arranging an array of light-emitting diodes on a "printed circuit board 16" with a corresponding array of collimating lenses.
    • Motivation to Combine: Petitioner contended a POSITA would have been motivated to mount the LED array in Tawa’s lighting apparatus on a common circuit board as taught by Scharf. Both Tawa and Scharf were directed to creating uniform illumination from LED arrays. A POSITA would have recognized that Tawa's LEDs required electrical connections to function, and using a printed circuit board as taught by Scharf was a standard, straightforward, and predictable solution for integrating and powering an LED array.
    • Expectation of Success: There was a high expectation of success, as combining the teachings involved standard and conventional methods for providing electrical connections and power to LEDs. This was a well-known practice in the field of LED-based lighting systems.

  • Additional Grounds: Petitioner asserted that claims 1, 4-6, 8, 31, 39, and 43 were anticipated by or obvious over Tawa alone. Petitioner also asserted additional obviousness challenges against claim 9 based on the combination of Tawa and Scharf. These grounds relied on similar arguments regarding Tawa's disclosure of the core lens features.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial of the inter partes review (IPR) would be inappropriate.
    • Under §325(d) (Advanced Bionics factors): The primary references of Tawa, Shikama, and Scharf were never considered during the original prosecution of the ’162 patent, so the petition raised new arguments.
    • Under §314(a) (Fintiv factors): Petitioner argued the factors strongly favored institution. The parallel district court litigation was in its early stages with minimal investment from the parties. The trial date was more than a year after the Final Written Decision (FWD) deadline and was uncertain due to a crowded court docket. Critically, Petitioner stipulated that it would not pursue in the district court the same grounds on which IPR is instituted, thus avoiding duplicative efforts. Finally, Petitioner asserted that the merits of the unpatentability challenge were compelling.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1, 4-6, 8, 9, 31, 39, and 43 of the ’162 patent as unpatentable.