Samsung Electronics Co Ltd v. Keyless Licensing LLC

1. Case Identification

• Case #: IPR2025-00529
• 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 and 7-20

2. Patent Overview

• Title: Data Entry for Mobile Devices
• Brief Description: The ’144 patent discloses mobile phone devices with specific dimensional characteristics and touchscreen features. The invention focuses on a form factor with a large display covering most of the front surface, a thin body, and the absence of physical keys for data entry.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 7, and 8 are obvious over Pensjo

• Prior Art Relied Upon: Pensjo (European Patent Application # 1229428).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Pensjo, which discloses a portable touchscreen "smart phone," teaches or renders obvious all limitations of independent claim 1. Specifically, Pensjo was alleged to disclose a "practically rectangular-shaped housing" with a large touchscreen display that practically covers the entire front surface, can be used in portrait and landscape modes, and utilizes a virtual keyboard, thus not requiring a physical key on the front surface. Petitioner contended that modifying Pensjo's dimensions to meet the claimed length (ear-to-mouth distance), width (substantially shorter than length or approx. half of length), and thickness was a predictable design choice for improving portability and ergonomics.
  • Motivation to Combine: Not applicable (single reference ground). Petitioner argued a POSITA would have been motivated to make simple dimensional modifications to Pensjo's design to enhance portability and user comfort, which were known design goals at the time.
  • Expectation of Success: A POSITA would have had a high expectation of success in making these dimensional adjustments, as they involved applying known design principles to achieve predictable results without changing the device’s fundamental operation.
  • Key Aspects: Petitioner argued that claim 8, which recites a thickness less than 20% of the width, is not entitled to the patent's earliest priority date because this limitation was first introduced in 2020 without written description support in the original applications.

Ground 2: Claims 3, 4, and 15-19 are obvious over Pensjo in view of Benoit

• Prior Art Relied Upon: Pensjo (European Patent Application # 1229428) and Benoit (French Patent Application # 2830093).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground asserted that Pensjo's mobile device design would be rendered obvious when combined with Benoit's user interface teachings. Benoit discloses a human-machine interface for a PDA that displays "a series of icons" for launching programs. Petitioner argued Benoit teaches the limitations of claims 3 and 15 not explicitly found in Pensjo, namely displaying a plurality of application icons and using a "sweeping action" to scroll through them. A "brief touch" on an icon launches the corresponding application, meeting the limitation of claim 4.
  • Motivation to Combine: A POSITA would combine Benoit's UI with Pensjo's device to provide more screen real estate, improve navigation efficiency, and reduce wear on the touchscreen by distributing touch points. This combination was presented as a logical integration of a known software interface onto a suitable hardware platform to enhance functionality.
  • Expectation of Success: A POSITA would have reasonably expected success in implementing Benoit's software-based UI on a device like Pensjo. The modification was characterized as a routine software implementation on a device with the necessary hardware (processor, touchscreen) already in place.

Ground 3: Claims 5, 9-11, and 14 are obvious over Pensjo in view of Kobayashi and Jambhekar

• Prior Art Relied Upon: Pensjo (European Patent Application # 1229428), Kobayashi (United Kingdom Patent Application # 2331204), and Jambhekar (Patent 5,848,356).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed claims related to automatic screen orientation. While Pensjo discloses a device usable in both portrait and landscape modes, it does not teach automatic rotation. Petitioner asserted Kobayashi remedies this by teaching a portable device with pressure sensors to detect how a user is holding it and automatically rotate the display accordingly. Further, Jambhekar was cited for disclosing virtual keyboards that can be displayed in either portrait or landscape layouts to align with the screen's orientation. This combination was alleged to meet the limitations of claims 5 and 9(j) requiring the device to be adapted to display text entered via a keyboard in both landscape and portrait directions based on the device's orientation.
  • Motivation to Combine: A POSITA would combine these references to create a more intuitive and user-friendly device. Integrating Kobayashi’s orientation detection into Pensjo would automate a desirable feature. Adding Jambhekar’s orientation-specific keyboards would provide a natural typing experience, aligning the keyboard layout with the screen orientation, which was a known challenge for small-screen devices.
  • Expectation of Success: Success was expected because the combination involved integrating known sensor technology (from Kobayashi) and established software features (virtual keyboards from Jambhekar) into a standard mobile device platform (Pensjo), representing a straightforward application of existing technologies.

• Additional Grounds: Petitioner asserted additional obviousness challenges for claims 12, 13, and 20 based on combinations of Pensjo, Kobayashi, Jambhekar, and Benoit, relying on similar rationales to integrate UI features with automatic orientation capabilities.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary 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 was raised or could have been reasonably raised in an IPR.
• Petitioner also contended that denial under §325(d) is inappropriate because none of the prior art references asserted in the petition were considered by the Examiner during the original prosecution of the ’144 patent.

5. 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.