PTAB

PGR2024-00039

Samsung Electronics Co Ltd v. Oura Health Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wearable Computing Device
  • Brief Description: The ’702 patent relates to a finger-worn wearable computing device that monitors a user's biological signals. The device comprises an external housing, an internal housing with a transparent portion, and a flexible printed circuit board (PCB) with sensors disposed in a cavity between the housings.

3. Grounds for Unpatentability

Ground 1: Obviousness over a Single Reference - Claims 1, 5, 7, and 12-15 are obvious over Schröder.

  • Prior Art Relied Upon: Schröder (Patent 10,303,867).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schröder taught all limitations of independent claim 1. Schröder disclosed a finger-ring biometric sensing device with two ring halves (internal and external housing components) that define a cavity. This cavity housed a flexible "inlay" made of PET or Kapton, which Petitioner asserted was a flexible PCB configured to conform to the arc of the cavity. Schröder’s ring included biometric sensors (an infrared diode and sensor) coupled to the inlay to capture a vein image through "transparent regions, e.g., windows" in the internal housing. Petitioner contended Schröder's "chip module" included processors and its antenna coil served as a communication module.
    • Key Aspects: Petitioner asserted that a POSITA would have understood that Schröder's metal housing would require a transparent window for its optical sensors to function, thus rendering the "substantially transparent material" limitation obvious.

Ground 2: Obviousness over Core Device and Optical Design - Claims 2-4, 6, and 8-11 are obvious over Schröder in view of LeBoeuf.

  • Prior Art Relied Upon: Schröder (Patent 10,303,867) and LeBoeuf (Patent 8,700,111).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground combined Schröder's foundational ring structure with LeBoeuf's more detailed optical design. Petitioner argued LeBoeuf taught the limitations of various dependent claims related to the optical properties of the transparent material. LeBoeuf disclosed a finger ring with a "light transmissive material" and windows that incorporated "optical filters" to selectively pass, filter, modify, or alter wavelengths of light (claims 2-4, 6). LeBoeuf also taught using multiple light emitters at different wavelengths (e.g., visible and infrared) and positioning them at different radial locations to assess multiple biological parameters (claims 9-11).
    • Motivation to Combine: A POSITA would combine these references to enhance the sensor capabilities of Schröder's basic ring. LeBoeuf offered specific, improved designs for light guides and optical filters that would allow for more efficient and accurate detection of biological signals, a well-known goal in the field.
    • Expectation of Success: Petitioner asserted success was predictable because both references related to finger-worn biometric sensors and involved the routine integration of known optical components (filters, multiple LEDs) into a wearable device.

Ground 3: Obviousness over Core Device and Power Source Design - Claims 16-17 are obvious over Schröder in view of Mestas.

  • Prior Art Relied Upon: Schröder (Patent 10,303,867) and Mestas (Application # 2014/0244009).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims 16 and 17 by incorporating a curved battery into Schröder's ring design. Petitioner argued Mestas taught a wearable device with a "curvilinear or curved configuration" battery that was electrically coupled to the device's components (claim 16). Mestas showed this curved battery positioned within recessed compartments of the device's housing, such that the arc of the battery approximated the arc of the device's cavity (claim 17).
    • Motivation to Combine: A POSITA would combine Schröder with Mestas to improve the power source of the finger ring. Implementing a curved battery as taught by Mestas would allow for a larger battery that conforms to the circular shape of the ring, increasing battery life without increasing device thickness or stressing the components.
    • Expectation of Success: Success would be expected as both references are in the analogous art of wearable electronics. Modifying a device's form factor to incorporate a conforming, curved battery was a predictable design choice to optimize space and power in a compact device like a ring.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds where LeBoeuf was the primary reference in view of Schröder. Other grounds further combined Schröder and LeBoeuf with Niwa (Application # 2012/0016245) to add teachings of specific multi-LED sensor layouts.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §325(d), stating that the primary references (Schröder, Niwa, Mestas) were never before the examiner. While a continuation of LeBoeuf was on an IDS with 139 other references, Petitioner contended it was not meaningfully considered, and the examiner materially erred by not applying its clear teachings.
  • Petitioner argued against discretionary denial under Fintiv because there was no pending district court litigation involving the ’702 patent, making the Fintiv factors inapplicable.

5. Relief Requested

  • Petitioner requests institution of Post-Grant Review and cancellation of claims 1-17 of the ’702 patent as unpatentable under 35 U.S.C. §103.