Samsung Electronics Co Ltd v. CM HK Ltd

1. Case Identification

• Case Number: IPR2025-01234
• Patent #: 10,852,846
• Filed: May 20, 2025
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): CM HK LIMITED
• Challenged Claims: 1, 3, 7, and 9

2. Patent Overview

• Title: Method for Determining Movements and Rotations in Dynamic Environments
• Brief Description: The ’846 patent relates to 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) and a computing processor to calculate deviation angles (yaw, pitch, roll) by processing sensor data through a looped algorithm involving multiple quaternions representing previous, current, and updated states.

3. Grounds for Unpatentability

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

• Prior Art Relied Upon: WO 2009/156499 to Bassompiere et al. (Bassompiere).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Bassompiere discloses all elements of the challenged claims. Bassompiere describes a 3D pointing device with a gyroscope (rotation sensor) and accelerometer that uses a microprocessor to run an extended Kalman filter (EKF) algorithm to estimate the device's pitch and roll angles. Petitioner contended that this EKF algorithm performs the same fundamental steps as the method in claim 1. Specifically, the EKF uses an output from a previous iteration (k-1) and measured sensor data from the current iteration (k) to calculate a corrected, updated orientation.
  • Motivation to Combine (Implicit Modification): While Bassompiere primarily describes its EKF using Euler angles, it explicitly discloses that the state vector can be a quaternion to avoid the computational complexity of sines and cosines. Petitioner asserted that a person of ordinary skill in the art (POSA) would have been motivated to implement Bassompiere’s EKF using quaternions, as this was a well-known and advantageous technique for sensor fusion. The patent owner's expert in related IPRs allegedly admitted that quaternion mathematics was within the level of ordinary skill.
  • Expectation of Success: A POSA would have a reasonable expectation of success in using quaternions in Bassompiere’s EKF because quaternions were widely used in sensor fusion algorithms to improve computational efficiency. The petition argued that converting the EKF equations from Euler angles to quaternions involves standard, well-known mathematical operations.
  • Key Aspects: The core of this ground is that Bassompiere’s EKF, when implemented with the explicitly suggested and well-known quaternion mathematics, reads directly on the claimed process. The petition mapped the steps of the EKF to the claim limitations: (1) using the previous state (k-1) maps to the "previous quaternion"; (2) using current gyroscope readings to predict a new state maps to the "current quaternion" and "predicted axial accelerations"; (3) comparing this prediction with measured accelerometer data maps to the "first comparison result"; and (4) calculating a corrected state maps to the "updated quaternion."

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

• Prior Art Relied Upon: Bassompiere, Patent 8,462,109 to Nasiri (Nasiri).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed an alternative claim interpretation where the "electronic device" of claim 1 must comprise the motion sensor module and the display device in the same housing. While Bassompiere’s main embodiment shows a separate pointer and screen, Nasiri discloses a mobile phone with a built-in display, gyroscope, and accelerometer, all within a single housing, for use in handheld gaming.
  • Motivation to Combine: Petitioner argued a POSA would be motivated to combine Bassompiere's sophisticated EKF sensor fusion algorithm with Nasiri's integrated hardware platform. Bassompiere explicitly identifies gaming as a key application where its technology, particularly its use of a three-axis gyroscope, is advantageous for tracking large-amplitude movements. A POSA would therefore look to implement Bassompiere's superior tracking algorithm on a common gaming platform like the mobile device taught by Nasiri to create an improved gaming experience.
  • Expectation of Success: A POSA would have a high expectation of success because the combination merely involved applying a known algorithm (from Bassompiere) to a suitable and known hardware environment (from Nasiri). The petition cited testimony from the patent owner's expert in a related case, admitting that a POSA would have been able to adapt orientation mapping for a built-in display.

4. Key Claim Construction Positions

• "spatial reference frame": Petitioner argued this term 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 construction, based on a prior PTAB decision for a related patent, establishes that the frame is body-fixed to the device. Petitioner contended that the reference frame (XYZ) in Bassompiere is a body-fixed frame that meets this construction.

5. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner dedicated a substantial section to arguing the ’846 patent is not entitled to the filing date of its provisional ’558 application. Petitioner asserted the ’558 application fails to provide written description support under §112 for the claimed use of quaternions. The provisional allegedly discloses the invention only in terms of Euler angles and lacks any mention of quaternions, the quaternion-based EKF equations, or the claimed comparison between predicted and measured accelerations. Therefore, the effective filing date is no earlier than November 11, 2010, rendering Bassompiere (published Dec. 30, 2009) and Nasiri (filed June 16, 2009) valid prior art.

6. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) would be inappropriate. Although U.S. equivalents of Bassompiere and Nasiri were considered during prosecution, Petitioner asserted they were never applied by the Examiner in any rejection. Thus, the Board would be considering these references and the specific invalidity arguments for the first time.

7. Relief Requested

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