PTAB

IPR2025-01254

Samsung Electronics Co Ltd v. Omni MedSci Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wearable Physiological Measurement System
  • Brief Description: The ’475 patent discloses a wearable apparatus for measuring physiological parameters like pulse rate and blood flow. The system uses a light source (LEDs) and a detection system to generate an output signal, employing techniques to improve the signal-to-noise ratio, and can communicate data to external devices like smartphones.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lisogurski and POSITA Knowledge - Claims 1, 8, 11-13 are obvious over Lisogurski in combination with the knowledge of a POSITA.

  • 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 sensor (light source and detector) and a separate monitor, teaches nearly all limitations of the challenged claims. This includes using multiple LEDs, spatially separated detectors, synchronizing the detector to the light source, and employing a "dark subtraction" technique (measuring with LEDs off and on) to improve the signal-to-noise ratio. Lisogurski also discloses detecting a "probe-off signal," which informs whether the device is being worn.
    • Motivation to Combine (for §103 grounds): Petitioner asserted that a POSITA would be motivated to modify Lisogurski's system by relocating the processing circuitry (control, light drive, and front-end processing) from the monitor to the sensor itself. Lisogurski expressly suggests that the functionality of components can be combined into a single component. This modification would create a self-contained, wearable biosensor, consistent with industry trends toward smaller, integrated wearable devices.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as combining processing circuitry into a sensor was a well-known design choice that would predictably result in a more compact and efficient device.

Ground 2: Obviousness over Lisogurski and Tran - Claims 5 and 7 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: This ground builds on the teachings of Lisogurski as established in Ground 1. For claim 5, Tran was cited for its disclosure of using artificial intelligence, specifically "artificial neural networks," to analyze physiological data from a wearable device to classify risks and provide warnings. For claim 7, Tran was cited for its disclosure of using a smartphone to collect and transmit data from a wearable sensor.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Lisogurski with Tran to improve the data analysis capabilities of the wearable sensor. Applying Tran's AI teachings to the data from Lisogurski's sensor would enhance the system's ability to track patient status and provide meaningful health alerts. Similarly, using a smartphone as the monitor, as taught by Tran, was a natural and obvious evolution for Lisogurski's portable system to facilitate communication and user interface.
    • Expectation of Success (for §103 grounds): The combination would predictably work, as applying known AI data analysis techniques and smartphone integration to a wearable physiological sensor were common and well-understood advancements in the art.

Ground 3: Obviousness over Lisogurski, Tran, and LeBoeuf - Claims 6 and 7 are obvious over Lisogurski, in view of Tran and further in view of LeBoeuf.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676), Tran (Patent 8,108,036), and LeBoeuf (Application # 2010/0217102).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses the limitation in claim 6 requiring that the detectors be "arranged along an arc." LeBoeuf discloses a physiological monitoring earbud with optical emitters and detectors explicitly disposed in an arc formation. Petitioner argued this teaching supplies the limitation missing from Lisogurski.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate LeBoeuf's arcuate arrangement of detectors into Lisogurski's sensor to improve the detection of scattered light from biological tissue. Because light scatters widely in tissue, an arc arrangement captures more of the reflected signal than a simple linear layout, thereby increasing the signal-to-noise ratio—a primary goal of the ’475 patent and a known objective in the field.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in applying LeBoeuf's sensor geometry to Lisogurski's sensor, as it was a known technique for improving signal capture in optical physiological measurement devices.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the above combinations further in view of Carlson (Application # 2005/0049468). Carlson was primarily cited for its teaching of using lenses to shape and direct light from LEDs to increase optical signal power without increasing actual power consumption, further supporting the obviousness of the claimed lens limitations.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be improper. Under §325(d), denial was argued to be inappropriate because the Examiner never issued a rejection and did not consider the specific prior art combinations asserted in the Petition, constituting a material error. Under §314(a) (Fintiv), Petitioner argued that the co-pending district court case is in its infancy, with a Markman hearing scheduled far in the future (February 2026), and that Petitioner stipulated not to pursue the same grounds in district court if IPR is instituted.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 5-8, and 11-13 of the ’475 patent as unpatentable under §103.