Samsung Electronics Co Ltd v. Cerence Operating Co

1. Case Identification

• Case #: IPR2025-00457
• Patent #: 7,680,334
• Filed: February 10, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics, America, Inc.
• Patent Owner(s): Cerence Operating Company
• Challenged Claims: 1-4, 8-10, 15-16, 19-22, 26-28

2. Patent Overview

• Title: Method for Presenting Recognized Handwritten Symbols
• Brief Description: The ’334 patent discloses methods for recognizing a handwritten pattern entered by a user. The system compares the input pattern to a plurality of stored templates, returns a "best template" or "best interpretation," and presents the result on a screen.

3. Grounds for Unpatentability

Ground 1A: Claims 1-2, 8-10, 15, 19-20, and 26-28 are obvious over Sinden in view of Fujisaki.

• Prior Art Relied Upon: Sinden (Patent 5,333,209) and Fujisaki (Patent 5,315,667).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Sinden taught the core method of a handwriting recognition system as claimed, including a processor and a digitizing tablet ("detection means") for capturing a user's handwritten symbol. Sinden’s system compared the unknown symbol to a library of "model symbols" (templates), calculated a correlation value to find the closest match ("returning a best template"), and displayed the result. Petitioner asserted that Sinden also disclosed using multiple templates for a single symbol to account for writing variations. While Sinden taught displaying the result, it allegedly lacked detail on displaying the pattern of the best template. Fujisaki, which addressed improving interactive training programs for similar systems, was argued to supply this missing element by explicitly teaching the display of the matched prototype’s handwritten pattern to the user.
  • Motivation to Combine: A POSITA would combine the references to improve the functionality of Sinden's "training mode." Petitioner contended that a POSITA seeking to implement Sinden’s training mode would have been motivated to look to references like Fujisaki for detailed implementation techniques, such as providing better user feedback by displaying the actual matched pattern.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because Sinden and Fujisaki described similar processor-based, on-line handwriting recognition systems, and implementing Fujisaki’s user interface teachings in Sinden’s system would have been a predictable improvement.

Ground 1B: Claims 3-4, 21, and 22 are obvious over Sinden in view of Fujisaki and Collins.

• Prior Art Relied Upon: Sinden (Patent 5,333,209), Fujisaki (Patent 5,315,667), and Collins (Patent 5,926,567).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Sinden-Fujisaki combination from Ground 1A. Petitioner argued that Collins taught specific techniques for efficiently displaying handwritten graphical data. For claim 3, Collins allegedly taught representing symbols as a series of sampled points (dots) and rendering an image by drawing lines between them. For claim 4, Petitioner asserted that Collins taught rendering a full bitmap image off-screen and then displaying the entire rendered image "at once" to provide an instant screen update, which would have been understood by a POSITA as "presenting the whole best handwriting symbol pattern ... at once."
  • Motivation to Combine: A POSITA would combine Collins with the Sinden-Fujisaki system to improve the speed and method of rendering the recognized handwriting symbol. Since the base combination already involved displaying graphical data, it would have been obvious to apply Collins' known techniques for faster rendering to this known device to achieve predictable results.
  • Expectation of Success: Petitioner argued for a high expectation of success because Collins expressly stated its teachings were applicable to handwriting recognition systems. Programming the Sinden-Fujisaki combination to render graphical data using the methods taught by Collins would have been within the skill of an ordinary artisan.

Ground 2: Claims 15 and 16 are obvious over Sinden in view of Fujisaki and Sklarew.

• Prior Art Relied Upon: Sinden (Patent 5,333,209), Fujisaki (Patent 5,315,667), and Sklarew (Patent 6,212,297).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed limitations in claims 15 and 16, where after a "best interpretation" is determined, a corresponding "best allograph" is retrieved from a database before being presented. Petitioner argued the Sinden-Fujisaki combination taught determining the best template and presenting an associated label. However, to the extent the combination did not explicitly teach retrieving this from a "database of allographs," Sklarew supplied this teaching. Sklarew disclosed a handwriting recognition system that stored associations between handwritten symbols and corresponding font symbols in a database. Upon recognition, the system retrieved the associated font symbol from the database for display. Petitioner equated Sklarew's font symbols with the claimed "allographs."
  • Motivation to Combine: A POSITA would combine Sklarew’s teachings to provide a known database architecture for the Sinden-Fujisaki system. Storing and retrieving symbol associations from a database was a common and logical implementation choice for maintaining relationships between recognized patterns and their corresponding display characters.
  • Expectation of Success: There was a reasonable expectation of success because Sinden and Sklarew disclosed similar handwriting recognition systems, and implementing a database as taught by Sklarew was a well-understood technique for improving such systems.

4. Key Claim Construction Positions

• Petitioner argued that the term "detection means for detecting entry of a handwritten symbol" in claims 1 and 15 was a means-plus-function limitation under §112, ¶6.
• The corresponding structure disclosed in the ’334 patent was identified as a pressure-sensitive screen (including its pressure-sensitive digitizer component), a scanner, an intelligent pen with a camera, and their equivalents.
• This construction was central to the invalidity argument, as Petitioner contended that Sinden’s disclosed "digitizing tablet or pad" which detects pen pressure was the same as or structurally equivalent to the patent’s disclosed "pressure-sensitive digitizer."

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv): Petitioner argued that discretionary denial under Fintiv would be inappropriate. It was contended that the early stage of the co-pending district court litigation (e.g., claim construction briefing not yet started), the Petitioner’s diligence, and the fact that the IPR challenges claims not asserted in the litigation all weigh against denial. Petitioner asserted that while the trial date is approximately 11 months after the petition filing, any FWD would issue only six months after trial, a timeframe the Board has previously found to weigh only marginally in favor of denial.
• §325(d): Petitioner argued against denial under §325(d), stating that the primary prior art references (Sinden, Fujisaki, Collins) were not disclosed or considered during the original prosecution. While Sklarew was cited in an IDS, it was not used in any rejection by the examiner, which Petitioner argued weighs strongly against discretionary denial.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-4, 8-10, 15-16, 19-22, and 26-28 of the ’334 patent as unpatentable.