Samsung Electronics Co Ltd v. CM HK Ltd

1. Case Identification

• Case #: IPR2025-01023
• Patent #: 10,852,846
• Filed: May 20, 2025
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): CM HK Ltd
• Challenged Claims: 1, 3, 7, and 9

2. Patent Overview

• Title: Method and Device for Determining Movements and Rotations
• Brief Description: The ’846 patent describes a method and electronic device for determining orientation in three-dimensional space. The system uses a motion sensor module (with a rotation sensor and accelerometer) to generate data that is processed using a recursive algorithm involving quaternions to calculate resulting deviation angles, which can be mapped to a display.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bassompiere - Claims 1, 3, 7, and 9 are obvious over Bassompiere.

• Prior Art Relied Upon: Bassompiere (International Publication No. WO 2009/156499).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Bassompiere taught a three-dimensional pointing device with a gyroscope and accelerometer that uses a sensor fusion algorithm, specifically an Extended Kalman Filter (EKF), to estimate the device's pitch and roll angles. The petition mapped the core computational steps of independent claim 1—such as providing a "previous" state (quaternion), converting measured angular velocities into a "current" state (quaternion), calculating "predicted" axial accelerations from the current state, and comparing them with "measured" axial accelerations to obtain an "updated" state (quaternion)—directly to the EKF equations disclosed by Bassompiere. While Bassompiere's primary embodiment used Euler angles, it explicitly taught that its state vector could be represented by quaternions. Dependent claims 3 and 9, which add utilizing a data association model, were argued to be met by Bassompiere’s EKF, which inherently uses a comparison model to determine compensation.
  • Motivation to Combine: The primary argument for obviousness rested on modifying Bassompiere’s EKF from using Euler angles to quaternions. Petitioner asserted a person of ordinary skill in the art (POSA) would be motivated to make this modification because Bassompiere itself stated that using a quaternion formulation avoids computationally intensive sine and cosine calculations. This benefit was well-known in the art for sensor fusion algorithms.
  • Expectation of Success: A POSA would have had a high expectation of success in implementing Bassompiere's EKF with quaternions, as quaternions were a standard and widely used tool for representing rotational motion in sensor fusion applications. Petitioner noted that Patent Owner's own expert in related proceedings admitted that quaternion mathematics was within the level of ordinary skill.

Ground 2: Obviousness over Bassompiere and Nasiri - Claims 1 and 3 are obvious over Bassompiere in view of Nasiri.

• Prior Art Relied Upon: Bassompiere (WO 2009/156499) and Nasiri (Patent 8,462,109).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented to preempt a potential claim construction requiring the "electronic device" to contain both the motion sensor module and the display device in the same housing. Petitioner argued Bassompiere taught the core EKF algorithm for orientation tracking, while Nasiri taught a mobile phone with a display screen, gyroscope, and accelerometer integrated into a single housing for applications like handheld gaming. Nasiri also used a sensor fusion algorithm to combine sensor data and determine the device's orientation relative to gravity.
  • Motivation to Combine: A POSA would combine Bassompiere's sophisticated EKF algorithm with Nasiri's integrated hardware platform for several reasons. Both references identified gaming as a key application. A POSA would be motivated to apply Bassompiere's more advanced EKF—which compensates for torsion and tilt—to the single-body device taught by Nasiri to create a superior mobile gaming device. Bassompiere explicitly discussed adapting its technology for gaming applications, motivating its use in a device like Nasiri's.
  • Expectation of Success: Petitioner contended a POSA would have a reasonable expectation of success because the combination involved applying a known algorithm (Bassompiere's EKF) to a known hardware configuration (Nasiri's integrated mobile device). This integration would be simpler than Bassompiere's system of separate components, as the spatial relationship between the sensors and the display would be fixed.

4. Key Claim Construction Positions

• Petitioner argued that the term "spatial reference frame" should be construed as a "reference frame associated with a 3D pointing device, which always has its origin at the same point in the device and in which the axes are always fixed with respect to the device."
• This proposed construction was based on a construction adopted by the Board in a prior inter partes review (IPR) of a related patent. The only modification was changing "the" to "a" to conform to the language of the challenged claims. Petitioner asserted this construction was consistent with the ’846 patent's specification, which describes a body-fixed coordinate system.

5. Key Technical Contentions (Beyond Claim Construction)

• Petitioner argued the ’846 patent is not entitled to claim priority to its provisional application (the ’558 application) filed on January 6, 2010.
• The argument asserted that the provisional application failed to provide adequate written description under 35 U.S.C. §112 for the claimed use of quaternions. The provisional allegedly disclosed orientation calculations using only Euler angles and did not describe or suggest converting to or using quaternions, nor did it describe the claimed step of comparing predicted and measured axial accelerations. This contention is critical for establishing Bassompiere (published Dec. 30, 2009) as prior art.

6. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. Although U.S. equivalents of Bassompiere and Nasiri were cited during prosecution, Petitioner asserted that the Examiner never raised the specific Bassompiere or Nasiri references in any rejection. Furthermore, the petition's arguments and application of these references were distinct from those considered during prosecution.

7. Relief Requested

• Petitioner requested institution of an IPR and cancellation of claims 1, 3, 7, and 9 of the ’846 patent as unpatentable.