PTAB

IPR2026-00164

Samsung Electronics America Inc v. Kiwi Intellectual Assets Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Duplex Electrical Connection Socket Structure
  • Brief Description: The ’307 patent discloses a reversible electrical socket structure designed for duplex electrical connections. The invention features a symmetric central tongue with rows of contacts on its first and second surfaces, arranged in a "functional reverse mirror configuration" to allow a corresponding plug to be inserted and establish a connection in two different orientations (e.g., right-side up or upside down).

3. Grounds for Unpatentability

Ground 1: Obviousness over Andre

  • Claims 34-39, 41-65, 67-75, 78-86, 88-96, 98-106, 114-120, and 130-135 are obvious over Andre.
    • Prior Art Relied Upon: Andre (Patent 7,094,089).
    • Core Argument for this Ground:
      • Prior Art Mapping: Petitioner argued that Andre discloses all limitations of the challenged claims under the Patent Owner's anticipated broad interpretation of key terms. Andre teaches a reversible receptacle with a symmetric insulating member (the claimed tongue) containing upper and lower contacts (first and second contacts). This structure allows a plug to be inserted at 0 or 180 degrees, establishing two separate operational states. Petitioner contended that Andre's design, where the plug's contacts engage both upper and lower receptacle contacts upon insertion, meets the limitation of being "operative to simultaneously electrically connect" as broadly interpreted. Andre's contact layout ("POWER," "DATA," "POWER") was argued to be a "functional reverse mirror configuration."

Ground 2: Obviousness over Andre in view of Lufan

  • Claims 34-120 and 130-135 are obvious over Andre in view of Lufan.
    • Prior Art Relied Upon: Andre (Patent 7,094,089) and Lufan (Chinese Patent No. CN201113094Y).
    • Core Argument for this Ground:
      • Prior Art Mapping: This ground asserted that even if Andre alone is insufficient, the combination with Lufan renders the claims obvious. Andre provides the fundamental streamlined, reversible, and symmetric connector design. Lufan teaches a USB socket with a nearly identical symmetric central tongue design that allows for reversible insertion. Crucially, Lufan explicitly discloses implementing a standard USB interface (VCC+, Data+, Data-, Ground) on both sides of the tongue in a reverse mirror configuration.
      • Motivation to Combine: A POSITA would combine Andre's user-friendly connector with Lufan's standard USB interface to enhance the connector's marketability and utility. Andre itself suggests its connector could be adapted for various data inputs, including USB. Given the structural similarities between Andre and Lufan, particularly the symmetric, reversible tongue, Lufan presented an obvious and logical source for a standard USB pinout to integrate into Andre's design.
      • Expectation of Success: A POSITA would have had a high expectation of success in this combination. The task involved applying a known element (Lufan's double-sided USB interface) to a known, similar electrical connector (Andre's socket) to achieve the predictable result of a reversible, double-sided USB connector.

Ground 4: Obviousness over Lufan, Yuming, and Lee

  • Claims 34-51, 53-96, 98-106, 108-114, 117-120, and 130-135 are obvious over Lufan in view of Yuming and Lee.

    • Prior Art Relied Upon: Lufan (Chinese Patent No. CN201113094Y), Yuming (Chinese Patent No. CN201204344Y), and Lee (Patent 6,854,984).
    • Core Argument for this Ground:
      • Prior Art Mapping: This ground was presented to address Petitioner's narrower claim construction, requiring a "dual-slot" socket that can accept two plugs simultaneously. Lufan teaches the base reversible USB socket with a central tongue. Yuming provides further conventional details for such a socket, including the physical relationship between the tongue and body and methods for affixing contacts. The key addition is Lee, which discloses a "Slim-USB-Plug" with the outer metal casing removed. Petitioner argued this design allows two such plugs to be inserted simultaneously into the top and bottom chambers of a dual-sided socket like that created by combining Lufan and Yuming.
      • Motivation to Combine: A POSITA would combine Lufan and Yuming to create a robust, reversible USB socket. This combination would then be further combined with Lee's caseless plug design to address the well-known need for connecting multiple plugs (e.g., two memory cards) in a small footprint. Lee explicitly addresses improving upon cumbersome standard plugs, and other art showed a trend toward multi-plug sockets.
      • Expectation of Success: Success was predictable, as it involved mating compatible, standard USB components. Lee's plug was designed to be compatible with standard USB sockets, and the Lufan-Yuming combination results in a socket with two standard USB interfaces, making the integration straightforward.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Andre, Lufan, Yuming, Zhenyu, Yen, Lee, and the USB3.0 specification, relying on similar theories of combining known reversible connector features with standard or enhanced USB interfaces.

4. Key Claim Construction Positions

  • Petitioner argued that prosecution history disclaimer and lexicography compel specific, narrower constructions for key terms than their plain and ordinary meaning might suggest.
  • simultaneously electrically connect / duplex electrical connection: Petitioner contended these terms require a "dual-slot" socket structure capable of having two separate plugs simultaneously connected. This argument was based on the patentee's statements during prosecution to distinguish prior art that allowed only a single plug to connect reversibly.
  • functional reverse mirror configuration: Petitioner asserted this term requires the socket's tongue to have "identical predetermined sequences of contact functions on both sides, in reverse order," as defined in the patent's specification with reference to two identical USB2.0 interfaces.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 34-39, 41-65, 67-75, 78-86, 88-96, 98-106, 114-120, and 130-135 of Patent RE50,307 as unpatentable.