PTAB

IPR2025-01251

Samsung Electronics Co Ltd v. Omni MedSci Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Physiological Measurement System
  • Brief Description: The ’304 patent discloses a physiological measurement system using a wearable device with semiconductor light sources and detectors. The system generates signals representing physiological parameters (e.g., blood oxygen saturation), which are transmitted to a smartphone or tablet and then to a cloud server for processing and storage.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lisogurski - Claims 1, 3, 11, 19, and 20 are obvious over Lisogurski.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lisogurski, which discloses a physiological monitoring system with a pulse oximetry sensor, teaches all limitations of the independent claims. Lisogurski’s sensor used multiple LEDs (a plurality of semiconductor sources) to non-invasively measure blood oxygen saturation. Petitioner asserted Lisogurski discloses techniques to improve signal-to-noise ratio (SNR), such as increasing light intensity and using a dark subtraction process that captures light when sources are on and off. The resulting data is processed by a monitor, which Petitioner contended a person of ordinary skill in the art (POSITA) would understand could be a portable device like a smartphone, and then transmitted wirelessly to a network server (a cloud).
    • Motivation to Combine (for §103 grounds): While this ground relied on a single reference, Petitioner argued a POSITA would find it obvious to modify Lisogurski by relocating the monitor's processing circuitry into the sensor itself to create a compact, integrated wearable device, consistent with industry trends toward miniaturization. Lisogurski itself suggested that the functionality of its components could be combined or divided.
    • Expectation of Success: A POSITA would have a high expectation of success in integrating the processing components into the sensor, as it involved combining known electronic components to achieve the predictable benefits of a smaller, more portable device.

Ground 2: Obviousness over Lisogurski in view of LeBoeuf - Claims 2, 4-6, 14-16, 21-22, and 27 are obvious over Lisogurski in view of LeBoeuf.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676) and LeBoeuf (Application # 2010/0217102).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that LeBoeuf, which discloses a light-guiding earbud for physiological monitoring, supplies the specific structural arrangements for light sources and detectors recited in the dependent claims. Specifically, LeBoeuf teaches arranging optical emitters and detectors along distinct, offset concentric arcs and using a reflective surface (a cladding material) to guide light and improve signal collection.
    • Motivation to Combine: A POSITA would combine LeBoeuf’s teachings with Lisogurski's system to solve the known problem of efficiently capturing scattered light from biological tissue. Arranging detectors in an arc as taught by LeBoeuf would improve the accuracy of Lisogurski’s sensor. Likewise, adding a reflective surface would enhance light delivery to the detectors, improving the SNR—a key objective disclosed in both Lisogurski and the ’304 patent.
    • Expectation of Success: The combination was predictable because both references address optical physiological monitoring. Applying a known sensor geometry (LeBoeuf's arcs) to improve signal detection in a known sensor system (Lisogurski) was a straightforward engineering task.

Ground 3: Obviousness over Lisogurski in view of Tran - Claims 1, 3, 11-13, 19, 20, and 26 are obvious over Lisogurski in view of Tran.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676) and Tran (Patent 8,108,036).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Tran teaches using a wearable appliance (e.g., a wristwatch) that transmits health data to a server for analysis by a statistical analyzer using artificial intelligence (AI), such as artificial neural networks. Tran’s system uses AI to perform pattern recognition on patient data to flag potentially dangerous conditions, thereby making decisions. This disclosure meets claim limitations requiring the use of AI for making decisions, performing pattern identification, and applying analytical methodologies.
    • Motivation to Combine: A POSITA would combine Tran’s AI-driven analysis with Lisogurski’s data-gathering system to make the collected physiological data more useful. Applying AI to analyze vital signs was a known method to improve the speed and accuracy of medical diagnosis and would have been a logical and obvious enhancement to Lisogurski’s system to provide automated warnings.
    • Expectation of Success: A POSITA would expect success in applying Tran’s known data analysis techniques to the data generated by Lisogurski’s sensor. The integration of software-based analytics with hardware sensors was a common and well-understood practice in the field.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Carlson (Application # 2005/0049468) to teach using lenses and specific light modulation frequencies to improve SNR, and Marbach (Patent 7,139,076) to teach applying multivariate analysis to improve measurement accuracy.

4. Key Claim Construction Positions

  • Petitioner argued that no special claim constructions were necessary, as the prior art disclosed the claimed features within their plain and ordinary meaning.
  • However, Petitioner noted that even under constructions adopted by the Board or district courts in cases involving related patents, the challenged claims were still obvious. For example, Petitioner referenced a prior construction of "modulating" to mean “varying the amplitude, frequency, or phase of the light produced by at least one of the LEDs to include information,” and argued Lisogurski’s system met this limitation by pulsing its LEDs on and off.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §325(d), asserting that although the primary references were cited during prosecution, they were never applied in a rejection, and the Examiner committed material error by not considering them in the combinations presented in the petition, especially given that identical claims in related patents had been invalidated on similar grounds.
  • Petitioner also argued against discretionary denial under Fintiv factors, stating its intent to seek a stay of the co-pending district court case. Petitioner further stipulated that if the IPR is instituted, it would not pursue the same grounds or combinations of the same prior art in the district court.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-6, 11-16, 19-22, and 26-27 of the ’304 patent as unpatentable under 35 U.S.C. §103.