PTAB

IPR2025-00689

Apple Inc v. SiOnyx LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Light Trapping Device
  • Brief Description: The ’714 patent describes a light trapping device for an image sensor that utilizes reflective layers of differing refractive indexes to reflect incident light back toward the image sensor’s pixel, thereby increasing light absorption efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-5, 9-11 over Hwang-099

  • Prior Art Relied Upon: Hwang-099 (Patent 7,675,099).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hwang-099 discloses all limitations of the challenged claims. Specifically, Hwang-099 teaches a light sensitive pixel with a light incident surface, a backside surface, and a peripheral sidewall formed by etching a trench. Hwang-099 further discloses both a backside light trapping material (base multi-layered reflection layer 155a) and a peripheral light trapping material (sidewall multi-layered reflection layer 220). Both reflective layers are described as comprising a "low-high-low sandwich" of materials with different refractive indexes (silicon oxide and silicon) to function as Bragg reflectors.
    • Motivation to Combine: Although based on a single reference, the argument combined teachings from different embodiments within Hwang-099. Petitioner asserted a person of ordinary skill in the art (POSITA) would be motivated to modify the embodiment of Hwang-099’s Figure 2 with teachings from its Figure 6 embodiment. This modification would extend the peripheral light trapping material to substantially cover the entire peripheral sidewall.
    • Expectation of Success: A POSITA would have a reasonable expectation of success (REOS) because the motivation was to increase the surface area of the light-trapping material on the sidewall, which would predictably increase the amount of light reflected back into the pixel. Hwang-099 provided known manufacturing methods for creating such structures.

Ground 2: Obviousness of Claims 1-5, 9-13 over Hong, Yamashita, and Hwang-584

  • Prior Art Relied Upon: Hong (Application # 2007/0108476), Yamashita (Application # 2011/0019050), and Hwang-584 (Korean Patent No. 10-0688584).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued this combination renders the claims obvious. Hong was asserted to teach the basic pixel structure, including a light sensitive pixel with a backside light trapping material in the form of a Distributed Bragg Reflector (DBR) mirror (reflective layer 204). Yamashita was added to teach modifying Hong's shallow trench isolation to create a peripheral sidewall that extends completely around the pixel in a lattice shape to prevent crosstalk. Finally, Hwang-584 was added to teach the peripheral light trapping material, specifically a device separation membrane (300) comprising alternating layers of materials with different refractive indices (silicon dioxide and silicon) that substantially covers the peripheral sidewall. This combination allegedly meets all limitations of independent claim 1.
    • Motivation to Combine: A POSITA would combine these references to solve known problems in image sensor design. Hong's pixel would be modified with Yamashita’s complete peripheral trench to solve the known problem of crosstalk between adjacent pixels. A POSITA would then be motivated to incorporate Hwang-584’s multi-layered reflective sidewall material into the trench taught by the Hong/Yamashita combination to further reduce crosstalk and improve light entrapment by reflecting long-wavelength light back into the pixel, a benefit expressly taught by Hwang-584.
    • Expectation of Success: A POSITA would have an REOS as the combination involved applying known techniques (trench etching, layered material deposition) to solve well-understood problems (crosstalk, light loss) in analogous image sensor devices.

  • Additional Grounds: Petitioner asserted 12 additional grounds. Grounds 2-7 built upon the primary Hwang-099 reference by adding secondary references to teach specific dependent claim limitations, such as particular high refractive index materials (Komuro), doped low refractive index materials (Hwang-795), frontside light trapping materials (Yamashita, Konno), sloped surfaces (Mouli, Nozaki), and specific aperture dimensions (Kim). Similarly, Grounds 9-14 built upon the primary Hong/Yamashita/Hwang-584 combination by adding the same set of secondary references to meet those same dependent claim limitations.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §314(a) and §325(d). Under the General Plastic factors, Petitioner asserted it has no significant relationship with Samsung, the petitioner in a prior-filed IPR (IPR2025-00161), as they are not co-defendants, have independent interests, and this petition presents materially different grounds (specifically, Grounds 8-14). Under the Fintiv factors, Petitioner argued that the parallel district court litigation is in its earliest stages, with a trial date not yet set and discovery just commencing, making it almost certain that a Final Written Decision in this inter partes review (IPR) would issue well before trial.

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-18 of the ’714 patent as unpatentable.