PTAB

IPR2025-00843

Suzhou Mojawa Intelligent Electronic Co Ltd v. Shenzhen Shokz Co Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Loudspeaker Apparatus
  • Brief Description: The ’582 patent discloses a modularly designed bone conduction headphone. The device features an ear hook surrounded by a protective sleeve, which connects a core housing containing an earphone core to a separate circuit housing containing a control circuit or battery.

3. Grounds for Unpatentability

Ground 1: Obviousness over Li and Liao - Claims 1 and 14 are obvious over Li in view of Liao.

  • Prior Art Relied Upon: Li (CN Publication # 107454492A) and Liao (CN Publication # 106937222A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Li disclosed the overall structure of a bone conduction earphone, including an ear hook, protective sleeve, core housing, and circuit housing. However, Li allegedly lacked specific details on the bone conduction speaker's design and vibration mechanism. Liao, a contemporaneous reference in the same field, was argued to supply these missing details, teaching a bone conduction speaker with a housing, a vibrating panel, and an energy conversion device that operates within the claimed frequency ranges. The combination of Li's overall structure with Liao's specific speaker design was asserted to render all limitations of independent claim 1 obvious.
    • Motivation to Combine: Petitioner contended a POSITA would combine Li and Liao to improve the sound quality of Li’s earphone. Since Li described a complete device but lacked speaker specifics, a POSITA would naturally look to known speaker designs like Liao's. Further motivation was alleged from the references sharing a common assignee and inventor and having similar open-ear, ear-hook designs, suggesting the combination was a predictable design choice.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining a known speaker type (Liao) into a known device platform (Li) was a straightforward application of known techniques to achieve predictable results.

Ground 2: Obviousness over Li, Liao, and Numata - Claims 7-12 are obvious over the combination of Li, Liao, and Numata.

  • Prior Art Relied Upon: Li (CN Publication # 107454492A), Liao (CN Publication # 106937222A), and Numata (JP Publication # 2008294872A).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Li-Liao combination to address claims 7-12, which recite specific mechanical connection features. Petitioner asserted that Numata taught a wireless headset with a robust plug-and-socket connection for its ear hook, including an insertion part with elastic hooks, a socket with an internal stopping block, and a U-shaped fastener. These features in Numata were argued to correspond to the claimed "first socket," "stopping block," "inserting portion," "elastic hooks," and "fastener" recited in the dependent claims.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to incorporate Numata's connection mechanism into the Li-Liao device to improve durability, wear-resistance, and the security of the modular connections. Li itself disclosed a need for a "tight fit," and Numata provided a specific, effective design to achieve this, motivating its inclusion to enhance the base device.
    • Expectation of Success: Success was expected because the combination involved implementing known mechanical fastening solutions (Numata) into a device with modular components (Li-Liao), a predictable area of design improvement for wearable electronics.

Ground 3: Obviousness over Multiple Magnetic Circuit References - Claims 16-20 are obvious over Li and Liao in view of Wang, Xu, and Nielsen.

  • Prior Art Relied Upon: Li, Liao, Wang (CN Utility Model # 205356672U), Xu (CN Utility Model # 205017577U), and Nielsen (WO # 2009/086838).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed the magnetic circuit component of the earphone core recited in claims 16-20. Petitioner argued that while Liao taught a basic "magnetic circuit system," the combination of Wang, Xu, and Nielsen disclosed the specific claimed configurations. Specifically, Wang and Xu were cited for teaching distinct magnetic units (first and second), conductive units, and magnetic gaps. Xu was argued to teach superimposing magnetic fields to increase flux density in the gap, and Nielsen was cited for teaching the use of an electrically conductive layer to reduce inductive reactance.
    • Motivation to Combine: A POSITA would combine these references to improve the magnetic circuit of the Li-Liao earphone. Petitioner asserted that Wang, Xu, and Nielsen each taught improvements—such as increased magnetic efficiency (Wang), higher magnetic flux density (Xu), and better performance in a compact design (Nielsen)—that were well-known design goals for speaker engineers. A POSITA would have been motivated to select from these known techniques to create a stronger, more efficient magnetic field.
    • Expectation of Success: The combination was asserted to be predictable, as all references were in the field of magnetic circuit speaker design, and their components were interoperable.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 2-6 based on Li, Liao, and Asaka (CN Utility Model # 202931524U). This ground relied on Asaka's teachings of using fixed sleeves or holding portions to secure wires within an ear hook during injection molding to improve manufacturing quality and durability.

4. Key Claim Construction Positions

  • Petitioner proposed a construction for a term in claim 5 to correct an alleged typographical error.
    • The phrase "the second wiring channel includes a second wiring groove and a second wiring hole connecting the second wiring groove and the outer end surface of the first plug end" should be construed to mean "...outer end surface of the second plug end."
    • Petitioner argued a POSITA would understand this as a typo because the claim context consistently addresses parallel "first" and "second" components, and a connection from the "second" channel to the "first" plug end would be illogical.

5. Arguments Regarding Discretionary Denial

  • Petitioner noted that, pursuant to the USPTO's March 26, 2025 Memorandum on PTAB Workload Management, it would not address discretionary denial issues in the petition itself.
  • Petitioner stated its intent to respond in an opposition brief if the Patent Owner files a separate brief raising discretionary denial arguments.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12, 14, and 16-20 of the ’582 patent as unpatentable.