PTAB

IPR2025-01481

BOE Technology Group Co Ltd v. Samsung Display Co Ltd

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petition

1. Case Identification

2. Patent Overview

  • Title: Flat Panel Display with Integrated Touch Screen Panel
  • Brief Description: The ’088 patent discloses a flat panel display, such as an OLED display, with an integrated touch panel. The touch-sensing components are formed directly on top of a "sealing thin film," which serves as an encapsulation layer to protect the underlying pixels from moisture and oxygen.

3. Grounds for Unpatentability

Ground 1A: Claims 1-13 are obvious over Chen, Jang, Sano, and Sakamoto

  • Prior Art Relied Upon: Chen (Patent 8,723,413), Jang (Application # 2010/0007616), Sano (Application # 2005/0156513), and Sakamoto (Japanese Publication JP2003317943).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chen taught the fundamental structure of an OLED display with a touch-sensor panel formed on a sealing (barrier) layer and wiring on the substrate. However, Chen lacked specific physical layout details. Sano was cited for its teaching of forming a more robust, multilayered sealing film with alternating organic and inorganic layers, which results in a "moderately inclined" surface at its edge to ensure complete protection of the underlying OLEDs. Jang was introduced to provide a conventional layout for an integrated touch panel, showing how sensing lines connect on-display sensors to a peripheral driving circuit, often via a flexible printed circuit board (FPCB). Finally, Sakamoto was relied upon to teach the known technique of depositing conductive lines along the side-slope or inclined surface of an insulating layer to connect components at different vertical elevations. The combination, Petitioner asserted, rendered the claimed invention obvious by using Sano's inclined sealing layer within Chen's device, arranging the wiring as shown in Jang, and using Sakamoto's deposition method to traverse the inclined surface.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to implement Chen's conceptual device with known, practical solutions. A POSITA implementing Chen's design would seek to improve the sealing layer for better OLED protection, leading them to Sano's well-known multilayer structure. To connect the touch sensors to drive circuitry—a detail not fully specified in Chen—a POSITA would look to a conventional layout like Jang's. The resulting height difference between the touch sensors on the sealing layer and the drive circuitry on the substrate would create a known problem of electrical connection, for which depositing lines along the inclined surface, as taught by Sakamoto, was a straightforward and superior solution compared to wire bonding or conductive vias.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success. The combination involved applying known solutions (Sano's sealing layer, Jang's layout, Sakamoto's connection method) to solve predictable problems (improving sealing, routing signals, connecting across a step) inherent in manufacturing the device described by Chen.

Ground 1B: Claims 1-13 are obvious over Chen, Matsuo, Sano, and Sakamoto

  • Prior Art Relied Upon: Chen (Patent 8,723,413), Matsuo (Application # 2008/0309635), Sano (Application # 2005/0156513), and Sakamoto (Japanese Publication JP2003317943).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1A, substituting Matsuo for Jang. Petitioner argued that Matsuo, like Jang, provided express instruction on the physical layout of a touch panel. Matsuo disclosed a top-down view of conductive metal wires ("sensing lines") that connect on-display touch sensors to off-display processors, with the wires extending outside the primary input region. Sano and Sakamoto were used for the same purposes as in Ground 1A: providing a multilayer sealing layer with an inclined edge and teaching the method for depositing conductive lines over that incline, respectively.
    • Motivation to Combine: The motivation was identical to Ground 1A, with Matsuo serving as another example of a well-known, conventional touch panel layout that a POSITA would have consulted to implement Chen's device. Petitioner argued that Matsuo merely provided express instruction for what was already implicit in Chen: that on-display sensors must connect to off-display circuitry.

Ground 2A/2B: Claims 1-13 are obvious over Imamura, Yang, and Sakamoto (and Chen)

  • Prior Art Relied Upon: Imamura (Application # 2003/0164674), Yang (Application # 2009/0085891), Sakamoto (Japanese Publication JP2003317943), and Chen (Patent 8,723,413) for Ground 2B.
  • Core Argument for this Ground:
    • Prior Art Mapping: This combination started with Imamura, which taught a sealed OLED display with a multilayered sealing membrane having an inclined surface, but without an integrated touch panel. Yang was cited for its teaching of integrating a capacitive touch panel, with its distinct electrode layers, onto a display device. Petitioner argued it would have been obvious to add Yang's touch panel on top of Imamura's existing sealed display. Sakamoto was again used to provide the solution for connecting Yang's touch sensors across the inclined surface of Imamura's sealing membrane to a driving circuit located in the non-display area. For Ground 2B, Chen was added to provide further detail on the structure of the touch-sensing circuit formed over a barrier layer, reinforcing the teachings of Yang.
    • Motivation to Combine: Petitioner argued that in 2010, there was a strong market trend and motivation to add touch functionality to displays. A POSITA starting with Imamura's sealed OLED would naturally be motivated to incorporate a touch panel. Yang provided an express teaching for doing so. This integration would create the same challenge of connecting the elevated touch sensors to the lower substrate circuitry, again motivating the use of Sakamoto's deposition technique over the inclined edge already present in Imamura.
    • Expectation of Success: Success was expected because integrating a touch panel onto a display was a routine and well-known process by 2010. The combination merely involved forming additional, conventional touch-panel layers (from Yang/Chen) on top of Imamura's display and using a known interconnection method (from Sakamoto).

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-13 of the ’088 patent as unpatentable.