PTAB

IPR2025-01071

Samsung Electronics Co Ltd v. CM HK Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Determining Deviation Angle of Three-Dimensional Pointing Device
  • Brief Description: The ’687 patent relates to a method and electronic device for determining the orientation of a three-dimensional (3D) pointing device. The system uses a motion sensor module and a processor to calculate deviation angles (yaw, pitch, roll) in a spatial reference frame by processing sensor data using quaternions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bassompiere - Claims 1-7, 12, 14, and 25 are obvious over Bassompiere.

  • Prior Art Relied Upon: Bassompiere (WO 2009/156499).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bassompiere discloses all elements of the challenged claims. Bassompiere teaches a 3D pointing device with a motion sensor module (including an accelerometer and gyroscope) and a computing processor that calculates the device's orientation. It uses a sensor fusion algorithm, specifically an extended Kalman filter (EKF), to process sensor data. The algorithm involves obtaining a previous orientation state, measuring current angular velocities, calculating a current orientation state, predicting axial accelerations based on that state, comparing them to measured accelerations to get a comparison result (error correction), and then obtaining an updated orientation. This updated orientation is then used as the previous state for the next loop, and the final deviation is used to provide visual content (e.g., cursor movement) on a screen.
    • Motivation to Combine (for §103 grounds): Petitioner contended that while Bassompiere primarily describes its EKF using Euler angles, it explicitly discloses that "the angles of torsion θ and ψ" can be replaced by a "quaternion formulation of the same torsion." Bassompiere stated this variant "exhibits the advantage of avoiding the computations of the sines and cosines... that are greedy in terms of computational power." Petitioner asserted that a POSA would therefore be motivated to implement Bassompiere’s EKF using quaternions—as claimed in the ’687 patent—to achieve the known benefits of improved computational efficiency and avoidance of issues like gimbal lock, which were well-known problems with Euler angles.
    • Expectation of Success (for §103 grounds): A POSA would have a reasonable expectation of success in substituting quaternions for Euler angles in Bassompiere’s system. Petitioner argued that the use of quaternions in sensor fusion algorithms like EKFs was well-known in the art, and Bassompiere itself provides the instruction to do so. The mathematical conversions between Euler angles and quaternions, and the equations for calculating predicted acceleration from a quaternion state, were all part of the common knowledge of a POSA.

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 is based on the patent’s specification and a similar construction adopted by the Board in a review of a related patent. The fixed nature of the frame relative to the device is critical to mapping the device's movements.

5. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Entitlement: Petitioner contended that the ’687 patent is not entitled to the January 6, 2010 filing date of its provisional ’558 application. The provisional application allegedly lacks written description support for the claims because it makes no mention of quaternions and describes its sensor fusion algorithms using only Euler angles. Therefore, the effective filing date is no earlier than November 11, 2010, making Bassompiere (published December 30, 2009) valid prior art under pre-AIA 35 U.S.C. §102(a).

6. Arguments Regarding Discretionary Denial

  • §325(d) Denial Inappropriate: Petitioner argued that discretionary denial under §325(d) would be inappropriate. Although a U.S. equivalent of Bassompiere was cited during prosecution of the ’687 patent, the examiner never raised the reference in any rejection. Petitioner asserted that Bassompiere was therefore not substantively considered by the Patent Office, and this IPR presents the first thorough examination of its teachings against the challenged claims.

7. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7, 12, 14, and 25 of the ’687 patent as unpatentable.