PTAB

IPR2025-01252

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 ’455 patent discloses a system for measuring physiological parameters using a wearable device. The device contains light sources and detectors to generate an output signal that is transmitted to a smartphone or tablet for processing, display, and potential communication with a cloud-based server.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lisogurski - Claims 1, 8, and 11

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lisogurski, a reference disclosing a physiological monitoring system, teaches every limitation of the challenged independent claims. Lisogurski’s system includes a sensor with light sources (LEDs) and detectors that can be worn on a wrist or ear, and a monitor that functions as a smartphone/tablet to process and display physiological data. Petitioner contended that Lisogurski discloses using multiple wavelengths, synchronizing the detection system with the light source, increasing light intensity to improve signal-to-noise ratio, and performing dark subtraction by comparing signals when the LEDs are on versus off.
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to modify Lisogurski’s monitor by relocating certain processing circuitry into the sensor itself to create a more compact, integrated wearable device, a modification Petitioner contended was expressly suggested by Lisogurski.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success as the proposed modification involved combining known components within a single device as suggested by the reference to improve portability and efficiency, which were common industry trends.

Ground 2: Obviousness over Lisogurski and LeBoeuf - Claims 2-4, 9-10, and 15-17

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676) and LeBoeuf (Application # 2010/0217102).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Lisogurski by adding LeBoeuf. Petitioner argued LeBoeuf, which discloses a light-guiding earbud for physiological monitoring, remedies any alleged deficiencies in Lisogurski regarding specific sensor configurations. LeBoeuf explicitly teaches arranging optical emitters and detectors in an arc formation to improve signal capture. It also discloses using a reflective surface within the earbud housing to redirect light and enhance the efficiency of light delivery to the user’s tissue.
    • Motivation to Combine (for §103 grounds): A POSITA would combine LeBoeuf’s arc-based sensor arrangement with Lisogurski’s system to improve the accuracy and reliability of measurements. Because light scatters widely in biological tissue, LeBoeuf’s arrangement of spatially separated detectors on an arc would capture more of the scattered light, thereby increasing the signal-to-noise ratio of Lisogurski’s wearable device.
    • Expectation of Success (for §103 grounds): Both references are in the same field of optical physiological monitoring and address similar problems. Combining their teachings to improve signal quality was a predictable and straightforward design choice.

Ground 3: Obviousness over Lisogurski, LeBoeuf, and Tran - Claims 1, 5-8, and 12-20

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676), LeBoeuf (Application # 2010/0217102), and Tran (Patent 8,108,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Tran to the combination of Lisogurski and LeBoeuf to address limitations related to data processing and artificial intelligence (AI). Petitioner asserted that Tran teaches a patient monitoring system that uses AI, such as artificial neural networks, to analyze physiological data from a wearable device. Tran’s system is configured to perform pattern identification, classification, and regression signal processing to track a patient’s health and warn of potential risks like stroke or heart attack.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Tran’s advanced data analysis techniques with the Lisogurski/LeBoeuf system to improve how the collected data is analyzed. Petitioner argued a POSITA would have been motivated to use Tran’s AI and pattern recognition methods to provide more accurate and meaningful analysis of the physiological data, allowing the system to recognize and flag dangerous conditions.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success because applying known data analysis techniques like AI and regression, as taught by Tran, to the physiological data stream from a sensor like Lisogurski’s was a well-known and predictable way to enhance system functionality.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Grounds 1-4 in further view of Carlson (Application # 2005/0049468). Carlson was introduced for its teachings on using lenses to increase optical signal power and modulating LED pulse rates to reduce interference from ambient light, thereby improving the signal-to-noise ratio.

4. Key Claim Construction Positions

  • “light source … configured to … increas[e] a pulse rate”: Petitioner noted that in a prior Final Written Decision (FWD) for a related patent, the Board construed this term to mean a light source capable of having its pulse rate increased to improve a signal-to-noise ratio. Petitioner argued the prior art meets this construction.
  • “to detect an object”: Petitioner referenced a prior FWD where the Board construed this term as “to discover or notice the existence or presence of something.” Petitioner contended that Lisogurski’s disclosure of generating a “probe off” signal when a sensor falls off a subject meets this construction.

5. Arguments Regarding Discretionary Denial

  • §325(d) - Same or Substantially Same Art/Arguments: Petitioner argued against discretionary denial because the Examiner did not substantively consider the relied-upon references during prosecution, even though they were cited in an Information Disclosure Statement. Petitioner asserted that the Examiner materially erred by allowing the claims, as the Board had previously found identical or substantially identical limitations unpatentable over the same prior art in related IPRs.
  • §314(a) - Fintiv Factors: Petitioner argued against discretionary denial under Fintiv, stating that the co-pending district court case is in its early stages, with a Markman hearing not scheduled until 2026. Petitioner stipulated it would not pursue the same invalidity grounds in district court if the IPR is instituted, and asserted the petition presents compelling unpatentability arguments that were overlooked during prosecution.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’455 patent as unpatentable under 35 U.S.C. §103.