PTAB

IPR2025-01231

Shenzhen Ronglida Technology Co Ltd v. Pathway IP LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Illuminator Device for a Web Camera
  • Brief Description: The ’729 patent discloses an illuminator device for webcams designed to provide uniform, shadow-free light for a user. The key embodiments describe an illuminator with a toroidal (ring-shaped) bulb and a conforming circular reflector that can be attached to a communication terminal via a positionable arm, or a plurality of lights integrated directly into the frame of a terminal surrounding the webcam.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 are obvious over Naghi and Dine

  • Prior Art Relied Upon: Naghi (Patent 6,799,861) and Dine (Patent 2,682,603).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Naghi taught a portable lighting apparatus with a light source on an adjustable, bendable arm with a clamp for attaching to devices like a laptop computer equipped with a webcam. Dine was cited for teaching a portable photographic lighting unit with a circular, toroidal bulb housed within a conforming annular chamber that acts as a circular reflector. Petitioner argued that combining Naghi’s positionable arm and clamp system with Dine’s superior toroidal light and reflector assembly meets all limitations of independent claim 1 and its corresponding dependent claims.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA), facing the well-known problem of poor lighting in webcam feeds, would be motivated to improve the illumination quality of a device like Naghi’s. Petitioner argued that Dine’s ring light, known for providing uniform and shadow-free illumination, presented an obvious solution. A POSITA would combine the references by substituting Naghi’s light source with Dine’s more effective lighting module to achieve the predictable result of improved facial illumination for a webcam user.
    • Expectation of Success: The combination was presented as a simple substitution of one known element (a basic light source) for another (a superior ring light) to yield predictable improvements in light quality.

Ground 2: Claims 1-7 are obvious over Nelson and Luo

  • Prior Art Relied Upon: Nelson (Application # 2007/0115672) and Luo (Chinese Utility Model Patent No. CN 2235130 Y).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a parallel argument to Ground 1 using a different set of prior art. Petitioner argued that Nelson disclosed a portable illuminating device with a light source on a flexible neck and a base with a clamp for removable attachment to articles like laptop computers. Luo was cited for disclosing a “shadowless” flash device featuring a toroidal lamp tube and a conforming circular reflector designed to eliminate shadows. Petitioner contended the combination of Nelson’s portable and attachable illuminator with Luo’s toroidal lamp and reflector teaches the limitations of claims 1-7.
    • Motivation to Combine: The motivation mirrored that of Ground 1. To solve the known issue of insufficient and uneven webcam lighting, a POSITA would be motivated to incorporate Luo’s toroidal lighting module into Nelson’s portable device. This combination would predictably enhance illumination quality for a user on a webcam.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination merely applied the known benefits of a ring flash (from Luo) to a portable webcam light (from Nelson).

Ground 3: Claims 10-13 are obvious over Du Breuil, either alone or in combination with Dine

  • Prior Art Relied Upon: Du Breuil (Application # 2007/0139515) and Dine (Patent 2,682,603).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted independent claim 10, which recites a plurality of bulbs integrated into the frame of a terminal, with at least one bulb surrounding the webcam. Petitioner argued Du Breuil taught a video telephone with light sources integrated into the frame of the screen assembly, adjacent to the camera. While the applicant overcame a rejection during prosecution by arguing Du Breuil’s lights were beneath the camera, not surrounding it, Petitioner contended that rearranging the lights to surround the camera would be an obvious modification.
    • Motivation to Combine (or Modify): Du Breuil itself recognized that improper lighting leads to dark and distorted images. Petitioner argued a POSITA would have been motivated to rearrange Du Breuil’s frame-mounted lights to optimize image quality, with surrounding the camera being one of a finite number of predictable solutions. Alternatively, Dine’s explicit teaching of surrounding a camera lens with a light source to achieve uniform, shadow-free illumination would have motivated a POSITA to modify Du Breuil’s design to gain the same known benefit.
    • Expectation of Success: Rearranging existing light elements into a different configuration to improve illumination was presented as a simple design choice with predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations, including Naghi/Dine/Cheng (for claim 7), Naghi/Dine/Cook (for claims 8-9), Nelson/Luo/Cook (for claims 8-9), Cheng/Masayuki (for claims 1-4, 7), Cheng/Masayuki/Nelson (for claims 5-6), and Cheng/Masayuki/Cook (for claims 8-9), which relied on similar substitution and design modification theories.

4. Key Claim Construction Positions

  • Petitioner argued in parallel district court litigation that terms in claim 1, such as “bulb having a toroidal shape” and “optimal viewing,” are indefinite under 35 U.S.C. §112.
  • However, for the purposes of this IPR, Petitioner asserted that the Board need not formally construe any claim terms. Petitioner maintained that the challenged claims are unpatentable over the cited prior art under any reasonable construction, including the Patent Owner’s proposed constructions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of the ’729 patent as unpatentable.