PTAB

IPR2025-01533

Shenzhen QIanfenyi Intelligent Technology Co Ltd v. WACom Co Ltd

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petition

1. Case Identification

2. Patent Overview

  • Title: ACTIVE PEN WITH BIDIRECTIONAL COMMUNICATION
  • Brief Description: The ’519 patent is directed to a processing system for an input device that facilitates bidirectional communication with a plurality of active pens, managing pairing and data transmission within defined time structures.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Sundara-Rajan - Claims 1-4, 7, 9, 10, 12-14, 17, 19-21, 23, and 24 are anticipated by or obvious over Sundara-Rajan under 35 U.S.C. §§ 102/103.

  • Prior Art Relied Upon: Sundara-Rajan (Patent 9,606,680).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Sundara-Rajan discloses a system for bidirectional communication between a computing device and an active stylus. It teaches a computing device transmitting a configuration ID or frequency ID (an upstream packet) to a stylus, which then configures its operation and transmits an "output sequence" of data, such as button status or pressure levels, back to the device (a downstream packet). Petitioner contended that a POSITA would understand that Sundara-Rajan's disclosure of a single stylus system could be readily applied to a system with multiple pens, thereby teaching the reception of downstream packets from a first and second active pen.
    • Motivation to Combine (for §103 grounds): For any limitations not explicitly disclosed, the motivation was to apply the known communication protocols taught by Sundara-Rajan to a second active pen, which Petitioner asserted was a simple and predictable extension of the disclosed system.
    • Expectation of Success: Success would be expected because applying the disclosed communication and synchronization methods to an additional, identical pen would involve only predictable engineering and known principles.

Ground 2: Obviousness over Sundara-Rajan in view of Kremin’926 - Claims 1, 2, 4, 7, 12-14, 17, 19, 21, and 24 are obvious over Sundara-Rajan in view of Kremin’926.

  • Prior Art Relied Upon: Sundara-Rajan (Patent 9,606,680) and Kremin’926 (Application # 2013/0207926).
  • Core Argument for this Ground:
    • Prior Art Mapping: To the extent Sundara-Rajan fails to explicitly teach managing multiple active styluses simultaneously, Petitioner argued Kremin’926 remedies this deficiency. Kremin’926 discloses synchronizing an active stylus with a capacitive array and concurrently detecting multiple touch objects. It teaches a host transmitting a synchronization signal that encodes timing and frequency information (a beacon signal) to an active stylus, which then demodulates the signal and transmits its own data back in the correct time intervals.
    • Motivation to Combine: A POSITA would combine these references to improve upon Sundara-Rajan’s system. While Sundara-Rajan teaches a versatile pen that can configure itself for different touch controllers, it provides minimal detail on managing multiple pens simultaneously. A POSITA would look to Kremin’926’s specific disclosure on synchronizing and managing multiple concurrent touch objects to implement a robust multi-pen system.
    • Expectation of Success: Both references operate in the same technical field of bidirectional stylus communication and address complementary problems. A POSITA would expect success in integrating Kremin’926’s multi-object synchronization methods with Sundara-Rajan’s self-configuring stylus technology.

Ground 3: Obviousness over Lefevre in view of Chandran - All Challenged Claims are obvious over Lefevre in view of Chandran.

  • Prior Art Relied Upon: Lefevre (Application # 2013/0157690) and Chandran (Patent 9,703,433).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lefevre teaches a general system for interfacing with a plurality of mobile elements (pens) in real-time. It describes a central processor broadcasting a "common activation signal" (a beacon) to initiate communication, with each mobile element responding in a designated timeslot. Chandran provides a specific protocol for implementing such a system on a capacitive touchscreen, disclosing a time-division multiplexed protocol where a panel sends a wake-up signal (which can be modulated to include a stylus ID) and styluses synchronize and respond. Chandran also explicitly addresses multi-stylus use and collision detection.
    • Motivation to Combine: A POSITA seeking to implement Lefevre's general concept of managing multiple mobile elements on a capacitive touchscreen would have been motivated to consult Chandran for a specific, compatible communication protocol. Chandran's detailed disclosure of a time-division multiplexed framework, stylus IDs, and collision handling provides a clear path to realizing Lefevre's broader objective in the specific context of active styluses.
    • Expectation of Success: Combining the references would have been expected to succeed because they share the common goal of enabling simultaneous interaction with multiple input objects. Integrating Chandran’s specific protocol into Lefevre’s general system framework is a predictable combination of known techniques to achieve a desired result.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 1, 4, 6, 12, 14, 16, and 20-22 based on Kremin’361 in view of Sundara-Rajan, relying on similar synchronization and collision management theories.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6, 7, 9, 10, 12-14, 16, 17, and 19-24 of the ’519 patent as unpatentable.