PTAB

IPR2025-01316

Samsung Electronics Co Ltd v. Maxell Ltd

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petition

1. Case Identification

2. Patent Overview

  • Title: Portable Terminal Apparatus for Remote Control
  • Brief Description: The ’646 patent discloses a portable terminal, such as a smartphone, that can remotely control an external device like a television. The invention focuses on improving user convenience by controlling how a remote control interface is displayed on the device's lock screen when it wakes from a sleep state, based on conditions such as prior use and network connectivity.

3. Grounds for Unpatentability

Ground 1: Obviousness over Esaka and Guihot - Claims 1-3, 7, 12-15, 19, and 24-25 are obvious over Esaka in view of Guihot.

  • Prior Art Relied Upon: Esaka (Patent 9,736,217) and Guihot (Patent 9,454,251).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Esaka and Guihot teaches all limitations of independent claims 1 and 14. Esaka disclosed a portable device (e.g., smartphone) that remotely controls a TV over a home network. Esaka taught displaying remote control icons on the lock screen only after confirming the device can communicate with the TV, otherwise displaying a standard lock screen. Guihot also disclosed using a smartphone as a remote control, teaching that to improve user experience, the remote control interface should be presented on the lock screen upon waking if the device was being used as a remote prior to entering a sleep state. The combination of Esaka’s network-awareness and Guihot’s prior-use context allegedly rendered the three conditional display modes of claim 1 obvious:
      • First Display Mode: A standard lock screen (no control icon) is shown if the device was not used as a remote before sleep (taught by Guihot).
      • Second Display Mode: A standard lock screen (no control icon) is shown if the device was used as a remote but cannot communicate with the external device (taught by Esaka).
      • Third Display Mode: A lock screen with a control icon is shown if the device was used as a remote and can communicate with the external device (combination of Esaka and Guihot).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Esaka and Guihot because both references addressed the same problem: improving user convenience by providing access to remote control functions from a locked screen. A POSITA would combine Esaka's network connectivity check with Guihot's prior-use check as a straightforward and predictable way to further refine the user interface and avoid displaying unusable controls, thereby achieving the stated goals of both references.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved implementing known software logic steps (checking network status and prior application use) to produce a predictable improvement in user interface usability, without requiring any hardware modification.

Ground 2: Obviousness over Esaka, Guihot, and Bandyopadhyay - Claims 4-6 and 16-18 are obvious over the combination of Esaka, Guihot, and Bandyopadhyay.

  • Prior Art Relied Upon: Esaka (Patent 9,736,217), Guihot (Patent 9,454,251), and Bandyopadhyay (Patent 9,521,247).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 by adding Bandyopadhyay to supply conventional smartphone hardware features recited in the dependent claims. Petitioner asserted that while Esaka and Guihot provided the core system, they lacked detail on common sensors and buttons. Bandyopadhyay allegedly disclosed these missing elements, including a GPS receiver (claim 4a), an accelerometer for determining movement state (claim 4b), an infrared proximity sensor (claim 4c), and a gyroscope (claim 4d). Bandyopadhyay also taught using physical buttons for predetermined operations, including single-button and simultaneous multi-button presses to launch an application (claims 4e, 5), and initiating an unlock operation by sliding an icon on the screen (claim 6).
    • Motivation to Combine: A POSITA would be motivated to add the conventional features taught by Bandyopadhyay to the base system of Esaka and Guihot to create a more complete and functional smartphone. Since Esaka and Guihot lacked detail on such common hardware, a POSITA would have naturally looked to other references in the field, like Bandyopadhyay, to implement these well-known sensors and physical button functionalities to enhance the device's capabilities and user interaction options.

Ground 3: Obviousness over Esaka, Guihot, and Sharif-Ahmadi - Claims 8-11 and 20-23 are obvious over the combination of Esaka, Guihot, and Sharif-Ahmadi.

  • Prior Art Relied Upon: Esaka (Patent 9,736,217), Guihot (Patent 9,454,251), and Sharif-Ahmadi (Patent 10,375,343).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Sharif-Ahmadi to the base combination of Esaka and Guihot to teach the wireless encryption limitations of claims 8-11 and 20-23. Petitioner argued that Esaka and Guihot disclosed wireless communication but were silent on security protocols. Sharif-Ahmadi remedied this deficiency by disclosing a system where a mobile phone controls a TV through a gateway that supports secure Wi-Fi communication. Sharif-Ahmadi explicitly taught implementing various encryption schemes, including WEP (Wired Equivalent Privacy), WPA (Wi-Fi Protected Access), and WPA2, which directly correspond to the limitations of the challenged dependent claims.
    • Motivation to Combine: A POSITA would have been motivated to incorporate the security features of Sharif-Ahmadi into the system of Esaka and Guihot to provide secure wireless communications, which was a well-known and desirable feature for network devices. As both Esaka and Guihot were concerned with secure and reliable operation, implementing standard, known encryption methods as taught by Sharif-Ahmadi would have been an obvious and necessary step to create a robust and secure commercial product.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of the ’646 patent as unpatentable.