Samsung Electronics Co Ltd v. Os New Horizon Personal Computing Solutions Ltd

1. Case Identification

• Case #: IPR2025-00613
• Patent #: 8,401,875
• Filed: February 20, 2025
• Petitioner(s): Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc.
• Patent Owner(s): OS-New Horizon Personal Computing Solutions Ltd.
• Challenged Claims: 1, 4, 7, 10, 14, 15, 18, and 19

2. Patent Overview

• Title: Apparatus for Managing Highly Secured Personal Data
• Brief Description: The ’875 patent describes an apparatus for securely managing personal data using a plurality of integrated biometric authentication systems. The apparatus also includes a "life signs detector" to prevent unauthorized access by confirming the presence of a live user, for instance by detecting if a life sign parameter falls below a critical level.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4, 7, 10, 14, and 19 are obvious over Fadell in view of Moran.

• Prior Art Relied Upon: Fadell (Application # 2009/0083847) and Moran (Patent 6,539,380).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Fadell discloses an electronic device with an embedded authentication system that uses a plurality of biometric sensors (e.g., fingerprint, facial pattern, handprint) to restrict access to device resources. Fadell also teaches countermeasures for "spoofing," including sensors for detecting a user's pulse and temperature, which correspond to the claimed "life signs detector." However, Petitioner asserted Fadell is silent on the specific implementation details of its authentication system. Moran was argued to supply these details, teaching an access control device implemented as a dedicated hardware chip that integrates a biometric detection device with its own processor and internal memory for storing reference biometric data. The combination of Fadell’s multi-biometric and liveness detection features with Moran’s secure hardware architecture allegedly renders the claims obvious.
  • Motivation to Combine: A POSITA would combine Moran’s specific hardware implementation with Fadell’s broader multi-biometric system to fill in Fadell's implementation gaps and improve security and performance. Moran expressly teaches that implementing the access control device as a separate chip is more difficult to "hack." Furthermore, using a dedicated processor/memory for authentication, as taught by Moran, would improve operational efficiency by avoiding competition with the device's main processor for resources.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success, as both references are in the field of biometric access control for portable electronic devices and Moran expressly discloses its access control device can be "directly integrated" into the device it controls.

Ground 2: Claims 1 and 4 are obvious over Kohinata in view of Mizusawa.

• Prior Art Relied Upon: Kohinata (Patent 6,788,928) and Mizusawa (Japanese Application # P2001-109855A).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner contended that Kohinata discloses a cellular phone with biometric authentication (fingerprint) and a "use detection module" that measures user temperature to ensure contact by a live person, satisfying the "life signs detector" limitation. However, Kohinata focuses on a single biometric modality. Mizusawa was argued to teach a flexible, multi-modal biometric system using both facial and fingerprint authentication. Mizusawa further discloses a "secondary authentication unit" that merges the results from the primary authentication methods to achieve higher accuracy. Combining Mizusawa's multi-modal approach with Kohinata's secure cellular phone platform allegedly renders the claims obvious.
  • Motivation to Combine: A POSITA would combine Mizusawa's multi-modal techniques with Kohinata's cellular phone to improve authentication reliability and security. Mizusawa expressly motivates using flexible multi-modal authentication to balance user burden with the required level of security, which is consistent with Kohinata’s goal of an "easy to use" yet secure phone. For functions requiring higher security, such as the financial transactions contemplated by Kohinata, a POSITA would be motivated to add Mizusawa’s multi-factor authentication to provide more robust protection.
  • Expectation of Success: Petitioner argued success would be predictable, as integrating multiple biometric authentication methods into cellular phones was well-known prior to the ’875 patent.

• Additional Grounds: Petitioner asserted additional obviousness challenges for claims 15 and 18 based on combinations that add Rosenblatt (Application # 2010/0082490) to the Fadell/Moran and Kohinata/Mizusawa combinations. Rosenblatt was argued to provide teachings of using an NFC (RFID-based) interface for communications with external devices like ATM machines and including an integrated GPS module for location-based services.

4. Key Claim Construction Positions

• Petitioner argued that the terms "first storage unit," "second storage unit," and "authentication unit" are means-plus-function terms under 35 U.S.C. § 112, para. 6.
• Petitioner contended these terms use the nonce word "unit" without reciting sufficiently definite structure for performing their respective functions (e.g., storing, comparing).
• Therefore, their scope should be limited to the corresponding structures disclosed in the ’875 patent specification and their equivalents. For example, the structure for "first storage unit" and "second storage unit" was identified as memory, and the structure for "authentication unit" was identified as a memory and a programmed processor.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv): Petitioner argued against discretionary denial, stating that the co-pending district court case is in its early stages. The trial is scheduled for June 2026, and a claim construction hearing is not scheduled until December 2025, well after an institution decision. Petitioner also stipulated that if the IPR is instituted, it will not pursue any instituted ground in the district court proceeding.
• §325(d): Petitioner contended that denial is inappropriate because the petition presents new art and arguments not before the examiner during prosecution. Specifically, Fadell was never considered, and Moran was not considered in combination with Fadell. Petitioner also argued that Fadell and Kohinata each disclose the "life signs detector" limitation, which was the key feature that the examiner found lacking in the prior art of record to allow the claims.

6. Relief Requested

• Petitioner requests the institution of an inter partes review and cancellation of claims 1, 4, 7, 10, 14, 15, 18, and 19 of the ’875 patent as unpatentable.