Samsung Electronics Co Ltd v. Keyless Licensing LLC

1. Case Identification

• Case #: IPR2025-00526
• Patent #: 9,304,602
• Filed: February 14, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Keyless Licensing LLC
• Challenged Claims: 1-13, 15-19, and 21-36

2. Patent Overview

• Title: System for Capturing Event Provided from Edge of Touch Screen
• Brief Description: The ’602 patent relates to a user interface for touch screen devices. The claimed system captures an event when a user performs a gliding action from outside the touch screen towards the inside, where the action first interacts with a predefined "window" or "zone" located on an edge of the screen to trigger a function.

3. Grounds for Unpatentability

Ground 1: Claims 1-13, 17-19, and 21-36 are obvious over Tseng

• Prior Art Relied Upon: Tseng (Application # 2009/0249247).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Tseng discloses a mobile device that meets all limitations of the challenged claims. Tseng’s "status bar" is the claimed "window" or "zone," located on the top edge of its touch screen, and it functions independently of the main application area. A user performs a "finger swipe" (the claimed "gliding action") on the status bar to pull down a "message area," which is the "action assigned to said window." Petitioner asserted that a person of ordinary skill in the art (POSITA) would have understood that a gliding action starting from the device's flush bezel and moving onto the screen would be registered by Tseng's device as a swipe originating on the status bar, thus disclosing the "from outside" limitation.
  • Motivation to Combine (if needed): In the alternative, Petitioner argued a POSITA would be motivated to apply a known off-screen-to-on-screen gesture to Tseng’s system. This modification would improve user experience by enabling easier, "low-precision" activation of the narrow status bar without requiring the user to precisely touch it, a known benefit for such gestures.
  • Expectation of Success: A POSITA would have reasonably expected to succeed in implementing an off-screen gesture, as it was a conventional technique whose application to Tseng’s interface would yield the predictable result of activating the pull-down notification menu.

Ground 2: Claims 1-13, 17-18, and 33 are obvious over Tseng in view of Wilairat

• Prior Art Relied Upon: Tseng (Application # 2009/0249247) and Wilairat (Application # 2010/0302172).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative for the "gliding action from outside" limitation. Tseng taught the base system with a status bar and pull-down menu. Wilairat explicitly taught detecting a "pull-in gesture" that a user initiates "just off an edge of the touch-screen" and moves across it.
  • Motivation to Combine: A POSITA would combine Wilairat's explicit off-screen gesture detection with Tseng's notification system to improve functionality. This would help the system differentiate intentional pull-down gestures from accidental touches on the status bar, allow for a thinner and less obtrusive status bar, and provide a more intuitive user interaction, all of which were known design goals in the art.
  • Expectation of Success: Implementing Wilairat’s known gesture detection method into Tseng’s system was a straightforward application of conventional techniques to achieve the predictable result of activating the pull-down menu.

Ground 3: Claims 1-13, 15-19, and 21-36 are obvious over Jeong

• Prior Art Relied Upon: Jeong (Application # 2009/0094562).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Jeong discloses a mobile terminal with activatable "tags" on the side and bottom edges of its touch screen. These tags were argued to be the claimed "window" or "zone." A user performs a "dragging" action (the claimed "gliding action") on a tag to expose a hidden menu screen of application icons. Jeong further disclosed that this action can be initiated from multiple edges of the screen. Petitioner contended that it would have been obvious to a POSITA to place these tags flush with the outermost edge of the screen to improve usability and make better use of screen real estate.
  • Motivation to Combine (if needed): A POSITA would be motivated to place Jeong’s tags at the absolute edge of the screen to simplify the user’s interaction, remove uncertainty about where to touch, and free up display area, consistent with known design principles for creating more efficient interfaces on small devices.
  • Expectation of Success: Modifying the placement of Jeong’s tags to the screen's edge was a simple design choice that a POSITA would expect to succeed in implementing to achieve a more efficient and reliable user interface.
• Additional Grounds: Petitioner asserted that claims 15-16, 18-19, and 21-36 are obvious over Tseng (or Tseng and Wilairat) in view of Hisatomi, which taught using multiple "drawer menus" on different screen edges. Petitioner also asserted an obviousness challenge to claims 1-13, 15-18, and 33 over Jeong in view of Wilairat.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate.
• Against Fintiv Denial: Petitioner stipulated, consistent with Sotera Wireless, Inc., that if the IPR is instituted, it will not pursue in the parallel district court litigation the same grounds asserted in the petition or any other grounds that could have been reasonably raised. Per the USPTO Director's Interim Procedure, such a stipulation weighs against discretionary denial.
• Against §325(d) Denial: Petitioner argued denial is not warranted because none of the primary prior art references (Tseng, Jeong, Wilairat, or Hisatomi) were before the Examiner during the original prosecution of the ’602 patent.

5. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 1-13, 15-19, and 21-36 of Patent 9,304,602 as unpatentable.