Samsung Electronics Co Ltd v. Keyless Licensing LLC

1. Case Identification

• Case #: IPR2025-00528
• Patent #: 11,503,144
• Filed: February 14, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Keyless Licensing LLC
• Challenged Claims: 1-5, 7-20

2. Patent Overview

• Title: Data Entry Method for Small Electronic Devices
• Brief Description: The ’144 patent discloses a mobile phone device with specific physical characteristics, including a thin, rectangular housing, an integrated display that covers nearly the entire front surface, and the absence of physical keys or buttons on the front surface. The invention also relates to user interface features for such a device.

3. Grounds for Unpatentability

Ground 1B: Obviousness over Bast and Wedel - Claims 1, 2, 7, and 8 are obvious over Bast in view of Wedel.

• Prior Art Relied Upon: Bast (European Application # EP1336949A1) and Wedel (International Publication # WO 2004/070871).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Bast disclosed a mobile device that met most limitations of claim 1, including a rectangular housing with integrated components, a large touchscreen, dimensions corresponding to ergonomic use (ear-to-mouth), a thin profile, and a buttonless front surface. Bast’s device was designed to make the screen "as large as possible" and was operable in both portrait and landscape modes.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Wedel’s teachings with Bast to further achieve Bast’s own stated goal of maximizing screen size. Wedel taught a method to increase the display area without increasing device thickness by integrating the speaker with the antenna behind the screen. Applying this known space-saving technique to Bast’s device was argued to be a predictable design improvement.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because both Bast and Wedel described mobile phones with similar architectures (e.g., rectangular housing, large touchscreen, speaker). Applying Wedel’s component placement strategy to Bast’s structurally similar device was a straightforward modification to yield the predictable result of a larger screen in a compact form factor.

Ground 2B: Obviousness over Bast, Wedel, and Benoit - Claims 3, 4, and 15-19 are obvious over Bast in view of Wedel and Benoit.

• Prior Art Relied Upon: Bast (European Application # EP1336949A1), Wedel (International Publication # WO 2004/070871), and Benoit (French Application # 2830093).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the Bast/Wedel combination by adding teachings from Benoit to address user interface limitations. Petitioner contended Benoit disclosed a human-machine interface for a touchscreen device where a user could scroll through a series of application icons via a "sweeping action" and launch a corresponding application by a "brief touch" on an icon.
  • Motivation to Combine: A POSITA would be motivated to incorporate Benoit’s UI features into the Bast/Wedel device to improve user experience. As the Bast/Wedel device was a PDA-like phone capable of displaying application icons, adding Benoit’s intuitive swiping and tapping functionality would be a logical step to simplify navigation and application launching, particularly when numerous applications are available.
  • Expectation of Success: The Bast/Wedel combination already provided the necessary hardware (touchscreen, processor). Implementing Benoit’s UI methods was a known software modification, and a POSITA would reasonably expect to successfully update the device’s software to enable these widely understood UI functions.

Ground 3B: Obviousness over Bast, Wedel, and Jambhekar - Claims 5, 9-11, and 14 are obvious over Bast in view of Wedel and Jambhekar.

• Prior Art Relied Upon: Bast (European Application # EP1336949A1), Wedel (International Publication # WO 2004/070871), and Jambhekar (Patent 5,848,356).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground added teachings from Jambhekar to address limitations related to text entry. Petitioner argued Jambhekar disclosed a mobile phone with a touchscreen that provided virtual keyboards for text input, with different keyboard layouts adapted for both portrait mode (e.g., for phonebook lookup) and landscape mode (e.g., for typing messages).
  • Motivation to Combine: The Bast/Wedel device already featured both portrait and landscape display modes for different viewing purposes. A POSITA would be motivated to integrate Jambhekar’s virtual keyboards to enhance the device’s functionality, providing an effective method for text input required for applications like email and messaging, which were central to such sophisticated devices.
  • Expectation of Success: The proposed modification was a logical extension of the Bast/Wedel device’s existing capabilities. Since the device already possessed a touchscreen and orientation-sensing technology, implementing Jambhekar's virtual keyboard functionality was a routine software update with a high probability of success.

• Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4B) for claims 12, 13, and 20 based on the combination of Bast, Wedel, Jambhekar, and Benoit, arguing it would have been obvious to merge the keyboard functionalities of Jambhekar with the UI navigation features of Benoit into the base device.

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: A central contention of the petition was that many of the challenged claims were not entitled to the earliest claimed priority date of April 18, 2003. Petitioner argued that key limitations—such as the "sweeping action" (claims 3, 12, 15-20) and a specific thickness-to-width ratio (claim 8)—were not disclosed in the specification or any priority application until amendments made as late as 2017 and 2020. This argument, if successful, would establish a later effective filing date for these claims, making more recent references available as prior art and subjecting the claims to AIA provisions.

5. Arguments Regarding Discretionary Denial

• Denial under Fintiv: Petitioner argued denial under Fintiv is not warranted because it stipulated that if the IPR is instituted, it will not pursue in the parallel district court litigation the specific grounds asserted in the petition, or any other ground that could have been reasonably raised.
• Denial under §325(d): Petitioner argued denial under §325(d) is not warranted because none of the prior art references or the specific invalidity arguments presented in the petition were considered by the Examiner during the original prosecution of the ’144 patent.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 7-20 of the ’144 patent as unpatentable.