PTAB

IPR2025-01313

Samsung Electronics America Inc v. Maxell Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Biometric Authentication and Information Display Between Paired Devices
  • Brief Description: The ’228 patent relates to a system comprising a first information processing device (e.g., a smartwatch) in communication with a second information processing device (e.g., a smartphone). The system uses static biometric information, such as a fingerprint, to authenticate a user on the second device, which then communicates with the first device to execute an unlock operation. The system also acquires dynamic biometric information from the first device to determine a user's state and displays information based on that state on the second device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Aminzade and Sowers - Claims 1-2, 4-7, 12-13, and 15-18 are obvious over Aminzade in view of Sowers.

  • Prior Art Relied Upon: Aminzade (Patent 8,976,965) and Sowers (Application # 2014/0343371).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Aminzade discloses the foundational system claimed in the ’228 patent: a smartphone that authenticates a user via a static biometric (e.g., fingerprint) and wirelessly communicates with a paired wearable device (a smartwatch) to unlock it. Petitioner contended that Sowers supplies the missing elements by teaching a wrist-worn health monitoring device that uses sensors (e.g., ECG, optical) to acquire dynamic biometric information (e.g., heart rate, body temperature) from a user and transmits this health data to a smartphone for analysis, display, and alerts.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Sowers's health monitoring technology with Aminzade's secure, paired-device framework to create a single, feature-rich product. Petitioner asserted that motivation arises from Sowers’s teachings on the desirability of continuous health monitoring and data security (HIPAA compliance), which would naturally lead a POSITA to integrate these features into Aminzade’s existing security-focused system.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because both references describe analogous smartphone-and-smartwatch ecosystems communicating via standard wireless protocols. Integrating Sowers's known sensor technology into Aminzade's wearable device was presented as a predictable design choice that would yield the claimed system.

Ground 2: Obviousness over Aminzade and Soli - Claims 1-2, 4-7, 12-13, and 15-18 are obvious over Aminzade in view of Soli.

  • Prior Art Relied Upon: Aminzade (Patent 8,976,965) and Soli (Application # 2015/0347711).
  • Core Argument for this Ground:
    • Prior Art Mapping: As in Ground 1, Petitioner relied on Aminzade for the core authentication and unlocking system between a smartphone and smartwatch. Soli was presented as an alternative to Sowers, disclosing a smartwatch with various sensors (e.g., photoplethysmogram, temperature sensor) that acquire dynamic "wellness data" (heart rate, blood pressure, etc.), transmit it to a smartphone, and display the aggregated information on the smartphone's screen.
    • Motivation to Combine (for §103 grounds): The motivation to combine stemmed from Soli's explicit disclosure of the consumer demand for monitoring and tracking wellness data. Petitioner argued a POSITA would find it a natural and obvious step to add this popular and known health-monitoring functionality to Aminzade’s general-purpose smartwatch platform to improve its utility and marketability.
    • Expectation of Success (for §103 grounds): The combination was argued to be predictable, as it involves integrating compatible technologies for a known purpose within similar hardware architectures.

Ground 3: Obviousness over Aminzade, Sowers, and Hong - Claims 3, 10-11, 14, and 21-22 are obvious over Aminzade, Sowers, and Hong.

  • Prior Art Relied Upon: Aminzade (Patent 8,976,965), Sowers (Application # 2014/0343371), and Hong (Application # 2015/0278498).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the base combination of Aminzade and Sowers to address more specific dependent claim limitations. Petitioner argued Hong teaches using Wi-Fi Direct for short-range communication between a smartphone and smartwatch, satisfying the limitations of claims 3 and 14. Further, Hong allegedly teaches determining that a user is in a specific state (e.g., "sleeping") and, based on that determination, limiting an operation by displaying a screen that seeks additional authentication (e.g., a password), satisfying the limitations of claims 10-11 and 21-22.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate Hong's teachings to improve the base system of Aminzade/Sowers. This includes adopting a known, efficient communication protocol (Wi-Fi Direct) and enhancing the system's security by adding context-aware authentication, which Petitioner described as a logical extension of Aminzade's existing security framework.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds substituting Soli for Sowers in combination with Hong (Ground 4), and grounds combining Aminzade/Sowers or Aminzade/Soli with Altman (Patent 8,099,109) to teach automatic transmission of position information (Grounds 5 and 6).

4. Key Claim Construction Positions

  • "performs communication" / "performing communication" (claims 1, 12): Petitioner argued this phrase should be construed to include not only sending but also receiving a transmission, as well as communication occurring within a single device (e.g., between internal components). This construction is central to mapping prior art where an instruction is received and processed internally by a device.
  • "unlock" (claims 1, 12): Petitioner proposed that the plain meaning of "unlock" includes any action that allows a user to access additional device functionality. This interpretation is broader than simply bypassing a lock screen and allows prior art that describes changing from a "reduced access mode" to an "increased access mode" to meet the claim limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-22 of Patent 10,783,228 as unpatentable under 35 U.S.C. §103.