PTAB

IPR2025-01556

Shenzhen Qianfenyi Intelligent Technology Co Ltd v. Wacom Co Ltd

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petition

1. Case Identification

2. Patent Overview

  • Title: Pulse- or Frame-Based Communication Using Active Stylus
  • Brief Description: The ’220 patent discloses techniques for an active stylus to communicate with a touch-sensitive device. The stylus captures data from internal sensors (e.g., pressure sensors, buttons), receives a carrier signal from the device, modulates the carrier signal with the captured sensor data, and transmits the modulated signal back to the device for demodulation and use.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kaneko and Vuppu - Claims 1-5, 7-11, and 13-17 are obvious over Kaneko in view of Vuppu.

  • Prior Art Relied Upon: Kaneko (Japanese Patent Publication No. JP 2008-152640) and Vuppu (Patent 8,766,954).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kaneko disclosed most limitations of the independent claims, including an electronic pen with sensors (e.g., pressure detection, electric field) that communicates with a touch panel. Kaneko's stylus receives a signal from the panel, modulates it with sensor data using amplitude modulation, and transmits the modulated signal back for demodulation. Petitioner asserted that Vuppu supplied the teaching of a stylus with a compound tip having distinct "receive" and "transmit" electrodes, a feature not explicitly detailed in Kaneko for its single electric field sensor, which was described primarily for receiving signals.
    • Motivation to Combine: A POSITA would combine Kaneko and Vuppu to predictably improve the functionality of Kaneko's stylus. Implementing Vuppu's dual-function electrode design would create a stronger, more robust, and more easily detectable signal from the stylus to the touch-sensitive device.
    • Expectation of Success: A POSITA would have had a high expectation of success in integrating Vuppu's known electrode configuration into Kaneko's stylus system to achieve the known benefit of improved signal strength.

Ground 2: Obviousness over Kaneko and Harley - Claims 1-5, 7-11, and 13-17 are obvious over Kaneko in view of Harley.

  • Prior Art Relied Upon: Kaneko (Japanese Patent Publication No. JP 2008-152640) and Harley (Patent 8,928,635).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Kaneko taught the core system, while Harley provided the teaching of a bi-directional electrode at the stylus tip capable of both sending and receiving signals. Harley was cited for disclosing an active stylus electrode that can function as both a drive element (to transmit) and a sense element (to receive) for signals via capacitive coupling with a touch sensor panel. This addresses the same limitation for which Vuppu was cited in the previous ground.
    • Motivation to Combine: A POSITA would combine Kaneko and Harley for the clear benefits of design simplification and cost reduction. While Kaneko used capacitive coupling for receiving signals and induction for other communications, adopting Harley's unified approach of using capacitive coupling for both transmitting and receiving would result in a simpler, less costly stylus design with fewer components.
    • Expectation of Success: The combination involved applying a known, simpler communication method (Harley's bi-directional capacitive coupling) to a known stylus system (Kaneko's) to achieve the predictable result of a more efficient design.

Ground 3: Anticipation and Obviousness over Kremin - Claims 1-5, 7-11, and 13-17 are anticipated by or obvious over Kremin.

  • Prior Art Relied Upon: Kremin (Application # 2012/0105362).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Kremin anticipated every limitation of the challenged claims. Kremin was asserted to disclose a complete stylus system featuring various sensors (force, acceleration, buttons) that communicates with a sensing device via capacitive coupling. Petitioner mapped how Kremin's stylus receives an initial signal from the device, uses that signal as a carrier, modulates sensor data onto this carrier, and transmits the resulting modulated signal back to the device. Kremin was also shown to disclose the use of multiple modulation schemes (amplitude, frequency, phase), the digitization of sensor data, and the transmission of specific pressure and button state data, thereby meeting all limitations of the independent and dependent claims.
    • Key Aspects: This ground relies on a single reference that allegedly teaches all claimed elements, making it primarily an anticipation challenge.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that the claims are obvious over Kaneko in view of Vuppu, Cao, and/or King-Smith (Ground 2); Kaneko in view of Harley, Cao, and/or King-Smith (Ground 4); and Kremin in view of Harley (Ground 6). These grounds relied on similar design modification theories but added references like Cao for teaching richer sensor data (e.g., gyroscopes) and King-Smith for teaching additional digital modulation techniques.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5, 7-11, and 13-17 of the ’220 patent as unpatentable.