PTAB

IPR2025-00953

Samsung Electronics Co Ltd v. Hermes IP Management LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Location-Based Service Method
  • Brief Description: The ’060 patent discloses a method for providing location-based services using photos taken by camera-equipped terminals. The method involves capturing an image, embedding location data into it, transmitting the enhanced image to another terminal, and then using the location data on the receiving terminal to initiate services like displaying a map or providing navigation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Singh, Abram, and Odashima - Claims 1, 4, 7-14 are obvious over Singh in view of Abram and Odashima.

  • Prior Art Relied Upon: Singh (Application # 2007/0195373), Abram (Patent 6,462,778), and Odashima (Japanese Patent Application Publication No. 2004-234562).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Singh, the primary reference, disclosed the core method of a location-based service: a camera phone captures a digital image, appends location metadata (e.g., from GPS), and transmits it to a receiving user’s device, which can then request a navigation path to the location. However, Singh did not explicitly teach prompting a user for consent before embedding location data or a specific user interface for selecting the service. Abram was argued to supply the missing prompt, teaching a menu that appears after image capture to let a user choose whether to associate location information with the image file. Odashima was argued to teach the user interface on the receiving terminal, disclosing a system that displays received images along with a menu of buttons (e.g., a "MAP" button) to request location-based services.
    • Motivation to Combine: A POSITA would combine Abram with Singh to provide user control over appending location data. This addresses the practical need to verify GPS data accuracy, a known issue, before it is shared and used for navigation. A POSITA would then incorporate Odashima’s user interface into the combined Singh/Abram system because it represented a known, intuitive method for a receiving user to view shared images and select from available location-based services, making the system more user-friendly and functional.
    • Expectation of Success: The combination was asserted to be predictable because all three references operate in the same technical field of mobile devices with cameras and location services. Integrating Abram’s software-based user prompt and Odashima’s user interface into Singh’s system involved applying known software techniques to similar devices to achieve a predictable improvement in user control and functionality.

Ground 2: Obviousness over Singh, Abram, Ogura, and Odashima - Claims 1, 4, 7-14 are obvious over Singh in view of Abram, Ogura, and Odashima.

  • Prior Art Relied Upon: Singh (Application # 2007/0195373), Abram (Patent 6,462,778), Ogura (Patent 6,995,792), and Odashima (Japanese Patent Application Publication No. 2004-234562).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Singh-Abram combination by adding Ogura to address the "predetermined location" limitation, in case it was interpreted as being determined by the terminal rather than the user. While Singh and Abram teach capturing an image at a location noticed by a user, Ogura was argued to explicitly teach a method where a device's GPS unit acquires and holds a positioning result in working memory before the user captures an image (e.g., upon powering the device on). This pre-acquired location data is only associated with the image data after capture.
    • Motivation to Combine: A POSITA would have been motivated to modify the Singh/Abram method with Ogura’s teaching to improve device performance. Ogura explicitly taught that performing positioning before photography reduces interference between the GPS and camera systems and lowers power consumption. This provided a clear reason to adopt Ogura’s technique of pre-acquiring location data to create a more efficient and reliable device. The remaining elements were taught by the base combination and Odashima for the same reasons as in Ground 1.

Ground 3: Obviousness over Singh, Abram, Odashima, and Suomela - Claims 3 and 6 are obvious over Singh in view of Abram, Odashima, and Suomela.

  • Prior Art Relied Upon: Singh (Application # 2007/0195373), Abram (Patent 6,462,778), Odashima (Japanese Patent Application Publication No. 2004-234562), and Suomela (Patent 7,480,567).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims 3 and 6, which added requirements for the content of the location-based service. The base combination of Singh-Abram-Odashima taught providing a location-based path, but not specific map or routing details. Suomela was argued to supply these missing details. Specifically, Suomela taught a mobile phone displaying a digital map that includes geographical information and highlights a recommended route to a destination (teaching claim 3’s map requirements). Suomela also explicitly disclosed using known pathfinding methods, such as Dijkstra's shortest path algorithm, to calculate the route (teaching claim 6’s "shortest route" requirement).
    • Motivation to Combine: A POSITA would combine Suomela with the primary combination to enhance the basic path-generation service. While Singh mentioned that path search algorithms were known, Suomela provided a concrete example of implementing a graphically rich map with shortest-route calculation on a similar mobile device. This combination represented a straightforward improvement to provide users with more detailed and useful navigation information, a clear and desirable goal in the art.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations that also included Bullock (Patent 6,810,323) to further reinforce that the same user could operate both the capturing and receiving terminals.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 3, 4, and 6-14 of the ’060 patent as unpatentable under 35 U.S.C. §103.