PTAB

IPR2025-01308

Samsung Electronics Co Ltd v. Maxell Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Content Receiving System
  • Brief Description: The ’650 patent relates to a content reproducing system comprising a main terminal that stores and distributes content to a plurality of subsidiary terminals. The main terminal uses association information to transmit specific content to a designated subsidiary terminal based on device-specific identification information.

3. Grounds for Unpatentability

Ground 1: Obviousness over Shindo - Claims 1-4 are obvious over Shindo.

  • Prior Art Relied Upon: Shindo (WO 2005/094080).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shindo discloses every limitation of the challenged claims. Shindo teaches a "linked display system" with a main "accumulation display device" (main terminal) and multiple "mobile information terminals" (subsidiary terminals). The main terminal includes a hard disk drive (HDD) for storing program content, a display unit, and a controller. This controller is configured to store terminal IDs (device specific ID information) for the mobile terminals and content IDs (content information). Petitioner asserted that Shindo's use of "trigger information" and "management information" constitutes the claimed association information, which links specific content to specific terminals. The system determines if a mobile terminal can connect and transmits content based on matching playback modes requested by the terminal and supported by the content. The mobile terminals are disclosed with their own controllers and displays for reproducing the received content.
    • Motivation to Combine (for §103 grounds): Not applicable (single reference ground).
    • Expectation of Success (for §103 grounds): Not applicable (single reference ground).

Ground 2: Obviousness over Sasaki - Claims 1-4 are obvious over Sasaki.

  • Prior Art Relied Upon: Sasaki (Japanese Patent Appl. Pub. No. 2003-208375).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Sasaki's information distribution system meets all claim limitations. Sasaki's "PC home server device" is a main terminal, and its multiple "personal digital assistants (PDAs)" are subsidiary terminals. The PC server includes storage (distribution content database, disks), a display, and a CPU that acts as the first controller. The CPU stores device-specific terminal IDs for each PDA and content identification information for content like electronic newspapers. Petitioner argued that Sasaki's "delimiter information," which identifies the last portion of content sent to a specific PDA, functions as the claimed association information. This allows the server to send the next correct segment of content to the correct PDA upon a subsequent request. The PDAs are described with their own CPUs (second controller) and displays.
    • Motivation to Combine (for §103 grounds): Not applicable (single reference ground).
    • Expectation of Success (for §103 grounds): Not applicable (single reference ground).

Ground 3: Obviousness over Futa and McClellan - Claims 1-4 are obvious over Futa in view of McClellan.

  • Prior Art Relied Upon: Futa (Application # 2004/0010687) and McClellan (Patent 5,619,250).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Futa, as the primary reference, discloses most elements of the claimed invention. Futa describes a content distribution system where a "broadcast receiving device" and a "data-communication controlling device" function collectively as a main terminal. This main terminal distributes content to subsidiary terminals like a TV and a PC. The main terminal stores content, device IDs, and content IDs, and uses "judgment tables" as association information to determine which content is permitted for transmission to a specific device. While Futa discloses the core system, it does not explicitly teach a display integrated with the main terminal. McClellan was introduced to supply this teaching, as it describes incorporating set-top boxes—which function like Futa's main terminal—directly into a television housing.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Futa and McClellan to integrate Futa's main terminal components into a television, as taught by McClellan. This would satisfy the consumer demand for integrated devices and was a well-known practice at the time for components like set-top boxes. The combination would yield the predictable result of a main terminal with an integrated display.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in this combination, as it involved incorporating a known type of system (a set-top box) into another (a television), a straightforward integration that required no undue experimentation.

4. Key Claim Construction Positions

  • Petitioner proposed a plain and ordinary meaning for the terms "first controller," "second controller," and "third controller." Petitioner argued there is a presumption that these terms do not invoke means-plus-function under 35 U.S.C. §112, as they do not recite the word "means." This construction is foundational to Petitioner's application of the prior art, which maps these limitations to general-purpose processors and controllers disclosed in the references.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4 of the ’650 patent as unpatentable.