PTAB

PGR2025-00063

Samsung Electronics Co Ltd v. Omni MedSci Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Physiological Measurement System
  • Brief Description: The ’475 patent discloses a physiological measurement system with a wearable device using light sources and detectors to generate an output signal. The signal, containing physiological parameters, is transmitted to a smartphone or tablet, which can communicate processed data to a cloud-based server for further analysis.

3. Grounds for Unpatentability

Ground 1: Claims 1, 8, and 11-13 are obvious over Lisogurski in view of POSITA knowledge.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lisogurski, a physiological monitoring system, discloses all elements of the independent claims, albeit with some processing components located in a separate monitor unit rather than integrated into the wearable sensor. Lisogurski's system includes a sensor with a light source (multiple LEDs) and detectors for measuring physiological parameters like pulse rate and blood flow. It also discloses techniques for improving signal-to-noise ratio by increasing light intensity and using a "dark subtraction" method, which Petitioner mapped to the differential measurement limitations. Further, Lisogurski was argued to disclose detecting a "probe-off signal" to determine if the sensor is worn by the user.
    • Motivation to Combine (for §103 grounds): Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have been motivated to modify Lisogurski’s system by relocating the monitor's front-end processing circuitry (including control and light drive circuitry) into the sensor itself. This modification was presented as an obvious design choice driven by industry trends toward creating more compact, power-efficient, and capable wearable sensors for fitness and health monitoring, thereby reducing latency and improving portability.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success, as integrating known processing circuitry into a sensor housing was a well-understood and common practice in the field.

Ground 2: Claims 5 and 7 are obvious over Lisogurski in view of Tran.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676) and Tran (Patent 8,108,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Lisogurski reference by adding Tran to address claim 5's limitation of using "artificial intelligence in making decisions." Tran discloses a patient monitoring system that uses artificial neural networks (a form of AI) to analyze physiological data, including pulse oximetry measurements, to classify risks and issue warnings. Tran also teaches using a smartphone to collect and transmit data from a wearable sensor, which Petitioner mapped to limitations in claim 7.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Lisogurski’s sensor with Tran’s AI-based analysis to improve the accuracy and predictive capability of the physiological monitoring system. Using Tran’s AI would allow the data from Lisogurski’s sensor to be processed more intelligently to identify trends or dangerous conditions.
    • Expectation of Success (for §103 grounds): The combination was argued to be predictable, as applying known data analysis techniques like AI to physiological sensor data was a well-established practice for improving monitoring systems.

Ground 3: Claims 6-7 are obvious over Lisogurski in view of LeBoeuf.

  • Prior Art Relied Upon: Lisogurski (Patent 9,241,676) and LeBoeuf (Application # 2010/0217102).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds LeBoeuf to address claim 6’s limitation requiring detectors to be "arranged along an arc." LeBoeuf discloses a light-guiding earbud with optical emitters and detectors disposed in an arc formation.
    • Motivation to Combine (for §103 grounds): A POSITA would have been motivated to arrange the detectors of Lisogurski’s sensor in an arc, as taught by LeBoeuf, to increase the accuracy of measurements. An arc formation allows for better capture of light that has been angularly scattered by biological tissue, thereby improving the signal-to-noise ratio.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success, as modifying the geometric layout of optical detectors was a known method for optimizing sensor performance.

  • Additional Grounds: Petitioner asserted that all claims were also obvious over the preceding combinations in further view of Carlson (Application # 2005/0049468). Carlson was introduced for its teaching of using beam-shaping lenses to increase the optical signal power detected by a sensor without increasing the actual power consumption, further improving the signal-to-noise ratio.

4. Key Claim Construction Positions

  • "modulating”/“modulation”: Petitioner noted that in prior related district court cases, the term “modulating at least one of the LEDs” was construed to mean “varying the amplitude, frequency, or phase of the light produced by at least one of the LEDs to include information.” Petitioner argued that the prior art, particularly Lisogurski's teaching of a "cardiac cycle modulation technique," discloses this limitation under the prior construction or its plain and ordinary meaning.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued strongly that discretionary denial would be improper.
    • Collateral Estoppel: Petitioner contended that Patent Owner is collaterally estopped from re-litigating the unpatentability of most challenged limitations. It was argued that identical or substantially similar limitations were already found unpatentable over the same Lisogurski-based art in Final Written Decisions (FWDs) for related patents in IPR2019-00916 and IPR2021-00453.
    • §325(d): Denial under §325(d) was asserted to be inappropriate because the Examiner never considered the specific prior art combinations raised in the petition during prosecution, even though the references were cited in an IDS.
    • §324(a) (Fintiv): Denial under the Fintiv factors was argued to be unwarranted because the co-pending district court case is in a very early stage, with a Markman hearing not scheduled until 2026, and Petitioners stipulated not to pursue the same grounds in that case if the PGR is instituted.

6. Relief Requested

  • Petitioner requests institution of Post Grant Review and cancellation of claims 1, 5-8, and 11-13 of the ’475 patent as unpatentable.