PTAB

IPR2026-00071

Samsung Electronics Co Ltd v. Kannuu Pty Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for selecting items from a database.
  • Brief Description: The ’939 patent describes a system for searching and selecting items from a database, such as contacts in an address book, using an input device with limited keys like a television remote. The system displays parts of "item identifiers" (e.g., letters) in a circular menu, allowing a user to progressively build a search term by selecting characters to narrow down the database results.

3. Grounds for Unpatentability

Ground 1: Claim 1 is anticipated or rendered obvious by Perlman.

  • Prior Art Relied Upon: Perlman (Application # 2002/0113825).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Perlman discloses every element of claim 1. Perlman describes a system for rapidly entering alphanumeric characters to select data, such as multimedia content on a television. It teaches a remote control with directional and select buttons arranged in a "star" pattern, which corresponds to an on-screen circular menu of characters. A processor associates items (media files) with item identifiers (their titles). A user selects an initial character (a part of an item identifier) from the on-screen menu, which filters a displayed list of items to show only those starting with that character. The system then generates a further display with new characters for selection, allowing the user to combine the selections to create a larger part of the item identifier (e.g., selecting "B" then "A" to form "BA"). This process inherently involves displaying parts of identifiers for mutually exclusive sets of items (e.g., items starting with "A" vs. "B").
    • Key Aspects: Petitioner noted that in prior inter partes review (IPR) proceedings on related patents, the Patent Trial and Appeal Board (PTAB) found that Perlman anticipated or rendered obvious substantially similar claims.

Ground 2: Claim 1 is obvious over Perlman in view of Dostie.

  • Prior Art Relied Upon: Perlman (’825 application), Dostie (Application # 2004/0021691).
  • Core Argument for this Ground:
    • Prior Art Mapping: To the extent Perlman is found not to explicitly teach the limitation that sets of items are "mutually exclusive," Petitioner asserted that Dostie supplies this disclosure. Dostie describes a data entry system that uses a hierarchical "tree structure" to organize its database for character prediction. In this structure, different branches of the tree represent mutually exclusive sets of items and their corresponding identifiers. The nodes within the tree represent subsets of items that are also mutually exclusive. Combining Dostie's well-known database structure with Perlman's user interface would result in the claimed invention.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to incorporate Dostie's efficient tree-based database searching into Perlman's system. Both documents address enhanced data entry and character prediction. Using hierarchical trees was a standard and well-known technique for improving the speed and efficiency of database searches, which is the stated goal of Perlman.
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining a known efficient database structure with a user interface for data entry was a routine and predictable design choice.

Ground 3: Claim 1 is anticipated or rendered obvious by Badarneh.

  • Prior Art Relied Upon: Badarneh (WO 2002/091160).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Badarneh discloses all limitations of claim 1. Badarneh teaches a system for data input on an electronic device using a rotatable, multifunctional switch with five pressure points (corresponding to up, down, left, right, and select functionalities). The system displays suggested letters in a circular menu based on a predictive algorithm that leverages a database of words. In response to a user selecting a first letter (e.g., "T"), the system generates a further display of additional letters (e.g., "E", "O", "H") corresponding to mutually exclusive subsets of items (e.g., items starting with "TE", "TO", or "TH"). The selected letters are combined and displayed to form a larger search term. Petitioner contended this system maps directly onto every element of the challenged claim.
    • Key Aspects: Petitioner noted that in prior reexaminations of related patents, the Central Reexamination Unit (CRU) found that Badarneh disclosed substantially similar claim limitations.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Perlman/Dostie/Josenhans (Application # 2002/0078013) and Badarneh/Josenhans to address alternative claim interpretations, such as a potential requirement that item sets be stored in separate physical databases. Josenhans was cited for its teaching of a unified search across multiple independent databases.

4. Key Claim Construction Positions

  • Term: "a remote control keypad with an up, down, left, right, select functionality"
  • Petitioner's Position: Petitioner argued that this term should be given its plain and ordinary meaning and should not be narrowly construed to require only four directional options. Petitioner noted that the claim requires five distinct functionalities (four directional plus select). This position is supported by the PTAB's rejection of the Patent Owner's proposed narrow construction for similar terms in prior IPRs involving related patents from the same family. Petitioner contended that no clear and unmistakable disclaimer was made during prosecution to limit the claim's scope in this manner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 1 of Patent 11,573,939 as unpatentable.