- Samsung Electronics Co., Ltd. / Samsung Electronics America, Inc. v. Ouraring, Inc.No claims unpatentablePTAB · Jul 10, 2026 · IPR2025-00147 · APJ Linda E Horner · IPR · Final written decision
The Board found claims 1–6 and 8–20 not shown unpatentable under three obviousness grounds, principally because the proposed combinations did not establish a feasible curved battery or transparent potting encapsulating the components.
RulingsFinal written decision- Skill levelSkill level board ownOther
“at least a four-year degree in electrical engineering, mechanical engineering, biomedical engineering, optical engineering, or related field of study, or equivalent experience, and at least two years’ experience in academia or industry studying or developing physiological monitoring devices such as non-invasive biosensors. Pet. 8 (citing Ex. 1002 ¶ 29). Petitioner also contends that a person of ordinary skill would have been “familiar with, e.g., sensor system design, including inertial and other motion sensor system design, and signal processing” and that “[a] higher level of education or skill might make up for less experience, and vice versa.” Id. Patent Owner agrees with Petitioner’s proposed definition of a person of ordinary skill in the art. Resp. 25. We adopt this uncontested definition of the level of ordinary skill in the art. This definition is supported by the record and consistent with the disclosure in the ’124 patent and the references cited in the Petition.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“We need not reach the issue of whether the preamble is limiting for purposes of determining patentability of the challenged claims. Even were we to agree with Patent Owner that the preamble is limiting and the claims are limited to a finger-worn ring wearable computer device, Petitioner has relied on Schröder in each ground to disclose a “wearable computing device configured to be worn around a finger of a wearer.” Pet. 22 (Ground 1), 45 (Ground 2, relying on Yuen for adding the functionality of light sources with a photodetector, temperature sensors, and varying the sampling frequency of sensor data acquisition), 56 (Ground 3). We agree with Petitioner that Schröder discloses such a device. Thus, no explicit claim construction is necessary for this decision.” slip op. at 11
- Obviousness (§103) › Motivation to combine / reasonable expectation of successReasonable expectation not foundNot shown unpatentableNot shown unpatentable
“We are not persuaded by Petitioner’s arguments and find that Patent Owner has the better position for several reasons. First, the record supports Patent Owner’s argument that Mestas’s batteries are much too large to fit within a ring form factor, and “would have to be reduced in size on the 6 There is no Exhibit 2022 in the record of this case. magnitude of 5-10x from its current size to fit in a ring of Schröder.” Resp. 38 (citing Dr. Anthony’s cross-examination testimony at Ex. 2021, 313:12). Second, Petitioner relies on evidence in the Reply that Petitioner failed to specifically identify in the Petition. Compare Reply 3–5 (citing Ex. 1369 ¶¶ 7–14; Ex. 1079 ¶¶ 47, 71; Ex. 2022, 138:7–143:1; Ex. 1002 ¶¶ 96, 337; Ex. 2021, 12–13, 307:7–17; Ex. 2020, 212:6–214:13; Ex. 1081, 130:18–131:14; Ex. 1010 ¶ 168), 9 (referring back to Section § II.B.2) with Pet. 25–26 (citing Ex. 1002 ¶¶ 193–99; Ex. 1010 ¶¶ 157, 163, 168, 201, Fig. 6). More specifically, while the portion of Dr. Anthony’s Declaration cited in the Petition (see Pet. 25–26 (citing Ex. 1002 ¶¶ 193–99)) mentions the Technology Background Section V of his Declaration (Ex. 1002 ¶¶ 42–147), neither Petitioner nor Dr. Anthony sufficiently explains what evidence supports his opinion that it was feasible to incorporate batteries or battery-like devices into finger-rings, or how a person of ordinary skill in the art would have miniaturized a curved battery for incorporation into Schröder’s ring. Ex. 1002 ¶ 196 (describing that rechargeable batteries powering wearable electronic devices were “well-known by 2013” and “had also undergone significant advances in terms of miniaturization and energy density [that] made it feasible to incorporate batteries or battery-like devices such as supercapacitors into smaller form factors, such as finger rings, without sacrificing functionality” such as “lithium-polymer (Li-Po) batteries and solid-state batteries.”). Moreover, some of Petitioner’s citations in the Reply appear to be incorrect as there is no Exhibit 2022 of record in this case, as noted above. These issues undermine the strength of Petitioner’s showing by making it difficult to follow its reasoning, much less identify where in the record that reasoning finds support. See DeSilva v. DiLeonardi, 181 F.3d 865, 866–67 (7th Cir. 1999) (“A brief must make all arguments accessible to the judges, rather than ask them to play archaeologist with the record.”); United States v. Dunkel, 927 F.2d 955, 956 (7th Cir. 1991) (“Judges are not like pigs, hunting for truffles buried in briefs.”). Third, even considering Petitioner’s new Reply arguments and” slip op. at 27
- Expert testimonyPatent owner expert creditedPetitioner expert discountedDecided for patent owner
“We credit Dr. Mercier’s testimony over Dr. Anthony’s and agree that Dr. Anthony’s testimony fails to account for the constraints of a substantially smaller form factor in Schröder’s finger-ring as compared to Mestas’s wrist device. Ex. 2018 ¶ 140. Although large curved batteries suitable for use in a wrist band or other larger wearable device, such as shown in Mestas, were known at the time of the ’124 patent, we also have evidence that prior art “finger ring wearables up to the ’124 patent had used ‘coin’ type batteries.” Resp. 40 (citing Ex. 2018 ¶ 140). We credit Dr. Mercier’s testimony that a person having ordinary skill in the art would have looked to a coin type battery for the necessary power requirements of Schröder’s device. Ex. 2018 ¶ 141. Indeed, this testimony is consistent with the other art of record that consistently shows the use of flat batteries in finger-ring devices, often stacked above and protruding from the general ring shape of the device. See, e.g., Ex. 1005 (Niwa), Figs. 22, 28; Ex. 2025 (Asada ’701 patent), Fig. 4; Ex. 1035 (Rhee), Figs. 7-1, 8-1, 8-2; Ex. 1037 (Asada article), Fig. 9; Ex. 1034 (Asada ’199 patent), Fig. 2; Ex. 1028 (Kimura patent), Fig. 24; Ex. 2018 ¶¶ 74–84. In fact, Oura’s first-generation ring design, released in 2015, used a Superbowl ring type design, with the battery and other components mounted on top of the ring. Ex. 2034; Ex. 2018 ¶ 85. We also agree with Dr. Mercier that Dr. Anthony’s testimony lacks evidence or a technical analysis of the power requirements for the various sensors he suggests including in a wearable device and the capacity of the proposed GMBPow battery. See, e.g., Ex. 1002 ¶¶ 94, 210, 214–17; Ex. 2018 ¶ 97. Moreover, Dr. Anthony does not address the issues with the batteries that are identified in the references he discusses. For example, Dr. Anthony does not address Lee’s disclosure that “direct coating of electrode slurry onto plain paper led to the occasional internal-shorting of the device due to the leakage of the electrode material through a large-sized hole in the paper.” Ex. 1019, 2415. In contrast, Dr. Mercier discusses the pitfalls the skilled artisan faced in developing finger-ring devices. See, e.g., Ex. 2018 ¶¶ 77–79 (discussing the issues Rhee’s and Asada’s large rings), 83 (identifying power requirements as a design constraint). For example, Dr. Mercier explains that “flexible or curved batteries include flexible packaging materials such as aluminum laminated films that house the electrodes and electrolyte” such that “once the battery packaging is added to a battery such as GMBPow and then placed within a housing (e.g., external housing shell and internal potting), the resulting device would have dimensions that are not suitable for a finger-worn ring.” Id. ¶ 96 (citing Ex. 2026).” slip op. at 34
Patent outcomesUS 11,188,124 not shown unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,188,124 - Blackberry Corp. / Blackberry Ltd. v. Zipit Wireless, Inc.No claims unpatentablePTAB · Mar 29, 2016 · IPR2014-01507 · APJ Trevor M Jefferson · IPR · Final written decision
Claims 1, 2, 5–12, 17–21, 24–31, and 36–40 were not shown unpatentable because the cited references did not teach or suggest graphical emoticons.
RulingsFinal written decision- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed patent owner constructionDecided for patent owner
“Based on the full record and consideration of the parties’ arguments and evidence, we determine that the broadest reasonable interpretation of the term “graphical symbols,” as would be understood by one of ordinary skill in the art, in the context of the entire disclosure is “graphical emoticon.” See Ex. 1001, 3:26– 36, 4:50–5:3, 7:4–23, 8:27–32, 8:43-46, 16:62–17:5, 18:46–55, 19:17–31, 20:1–14, Figs. 2, 12a, and 12b. We agree with Patent Owner that the Specification of the ’870 patent shows “symbols” being generated by textual characters. PO Resp. 14– 15. Specifically, the ’870 patent refers to characters generating graphical symbols where symbols are pictorial representations, e.g. , indicates to a person of ordinary skill in the art that symbols (and graphical symbols) are distinct from the textual characters used to generate them. Ex. 1001, 3:26–36, 4:50–5:3. Thus, we are not persuaded by Petitioner’s argument or the testimony of their Declarant that the ’870 patent Specification does not distinguish between characters and symbols. Reply 12–13. We find that the Specification of the ’870 patent showing combination of textual characters that are used to generate “graphical symbols” across different messaging services further supports the distinctions between textual characters and graphical symbols. See Ex. 1001, 7:20–23; 8:27–32, 8:43– 46, Tables 1–4.” slip op. at 15
- Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)Not shown unpatentableNot shown unpatentable
“Based on the complete record, we agree with Patent Owner that Petitioner has not demonstrated by a preponderance of the evidence that the e740 User’s Manual explicitly or inherently discloses the limitations of independent claims 1 and 20. See PO Resp. 35–37. The Petition applies a construction for “graphical symbol” that includes text emoticons and individual characters themselves as graphical symbols. See Pet. 14–15 (claim 1), 25 (claim 20), 28 n.3 (citing individual characters such as “)” and “-“ as graphical symbols alone). The Petition states that the “combination of characters, each element of the smiley face—‘:’, ‘-‘, ‘)’—is also a graphical symbol” like a “character sequence, such as ‘:-)’ or ‘;-)’, that represents a graphical symbol.” Pet. 28 n.3. Based on the claim construction determined above, “graphical symbols” are “graphical emoticons” that are distinct from “textual emoticons” presented by Petitioner. Petitioner’s evidence and argument do not establish that the cited reference teaches a “device [] configured to generate textual characters and graphical symbols” as recited in independent claims 1 and 20.” slip op. at 19
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable
“Petitioner’s argument and evidence rely on the same overly broad construction of “graphical symbols” used in the anticipation grounds based on the e740 User’s Manual. Pet. 35, 38, 43–44, 48, 55–56 (citing e740 User’s Manual for teaching recited claim limitations for graphical symbol). As discussed above, Petitioner’s argument that the combination of Morrison and the e740 User’s Manual teach “graphical symbols” is not supported by the Petition. Although we carefully weighed Patent Owner’s Declarant testimony, we agree with Patent Owner’s argument that the Petition fails to demonstrate that Morrison and the e740 User’s Manual teach or suggest “graphical symbols” or “graphical emoticons” as opposed to textual characters cited by Petitioner. PO Resp. 35–42, 43–46. We have considered the arguments and evidence presented by the Petitioner and Patent Owner. For the reasons discussed above, we conclude that Petitioner has not shown by a preponderance of the evidence that claims 1, 2, 5–8, 11, 12, 17, 18, 20, 21, 24–27, 30, 31, 36, 37, and 40 are obvious in view of the e740 User’s Manual and Symbol; claims 1, 2, 5–8, 11, 12, 17–21, 24–27, 30, 31, and 36–40 are obvious in view of e740 User’s Manual and Morrison; or claims 9, 10, 28, and 29 are obvious in view of e740 User’s Manual and e750 User’s Manual.” slip op. at 20
- ExcludeMotion to exclude, grantedGranted
“Although we did not rely on these exhibits or reach secondary consideration issues, Patent Owner’s belated introduction of summary evidence that Patent Owner admits is in the record with the Patent Owner response is cumulative. We grant Petitioner’s motion to exclude Exhibits 2080 and 2081.” slip op. at 21
Patent outcomesUS 7,292,870 not shown unpatentableClaim construction§ 102 anticipation§ 103 obviousnessPatents in suitUS 7,292,870
Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.