PTAB

IPR2026-00072

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 ’252 patent discloses a system for selecting items, such as names in an address book, on a television display. The system uses a remote control with a 4-way directional controller to navigate an on-screen display, allowing a user to progressively build an "item identifier" by selecting parts of it (e.g., letters) to narrow down a search.

3. Grounds for Unpatentability

Ground 1: Obviousness over Perlman and Lee - Claims 1-13 are obvious over Perlman in view of Lee.

  • Prior Art Relied Upon: Perlman (Application # 2002/0113825) and Lee (Patent 6,144,378).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Perlman discloses a system for selecting data on a television using a remote control to input characters from an on-screen display arranged in a "star" pattern. The system predictively updates a list of database items as characters are selected. Lee discloses a symbol entry system for a television that uses a handheld remote with up, down, left, and right keys and a central "action" key to navigate a circular on-screen menu and select characters. Petitioner asserted that combining Perlman's predictive database selection system with Lee's more efficient directional navigation method renders the limitations of claim 1 obvious. For example, Perlman’s system of updating a display with further parts of item identifiers after an initial selection, combined with Lee's method of using a 4-way controller to navigate and select those identifiers, meets the core limitations of claim 1.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Lee's navigation interface with Perlman's system to create a more efficient and user-friendly text entry method. Lee's directional navigation and selection is a well-understood improvement over Perlman's direct character-mapped buttons, as it can reduce input errors and improve the speed of character selection. This combination would be a predictable solution to the known problem of efficient text entry on devices with limited keyboards.
    • Expectation of Success: A POSITA would have a high expectation of success in making this combination. Both references address user input on a television screen via a remote control. Implementing Lee's navigation logic within Perlman's system would involve conventional user interface programming techniques that were well within the skill of an ordinary artisan.

Ground 2: Obviousness over Badarneh and Lee - Claims 1-5 and 7-13 are obvious over Badarneh in view of Lee.

  • Prior Art Relied Upon: Badarneh (WO 2002/091160) and Lee (Patent 6,144,378).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Badarneh discloses a predictive text input system for an electronic device with a display. It uses a rotatable, multifunctional switch to navigate and select characters from a circular menu to build a word. As a user selects letters, Badarneh offers suggestions for the next character or completed word. Petitioner argued that replacing Badarneh's input mechanism with Lee's more conventional 4-way directional controller would result in the claimed invention. The combination of Badarneh’s core predictive system with Lee’s directional controller for navigating and selecting characters meets the limitations of the challenged claims.
    • Motivation to Combine: A POSITA would be motivated to incorporate Lee’s simpler and more direct navigation method into Badarneh’s system. Lee expressly teaches that its interface is more "compact" and avoids the "very large cursor movements" required by other on-screen keyboards, providing a clear reason to prefer it over Badarneh's more cumbersome method of rotating a dial and then pressing a key. The motivation would be to improve the user interface for predictability and ease of use.
    • Expectation of Success: The combination would have been readily achievable with a high expectation of success. Both references are in the same field of remote text entry, and substituting one known input method (Lee's 4-way controller) for another (Badarneh's rotatable switch) is a simple and predictable design modification.
  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 6 and 11 based on combinations including Dostie (Application # 2004/0021691), arguing Dostie's disclosure of using a hierarchical tree structure for database searching was a well-known and obvious addition to the systems of Perlman or Badarneh to teach the "hierarchical tree" and "hierarchical classification" limitations.

4. Key Claim Construction Positions

  • Petitioner argued that the claim term "4-way directional controller" should be given its plain and ordinary meaning and should not be construed to require a system with only four directional selection options.
  • Petitioner supported this proposed construction by citing intrinsic evidence from the ’252 patent specification, which describes variations with different numbers of options. It also noted that in prior IPRs involving related patents, the Board had rejected the Patent Owner's attempts to import a similar "no more than four" limitation into the claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of Patent 11,200,252 as unpatentable.