Obviousness

Obviousness Analysis of U.S. Patent No. 8,738,103

This analysis evaluates the patentability of the independent claims of U.S. Patent No. 8,738,103 ("the '103 patent") under 35 U.S.C. § 103, focusing on whether the claimed invention would have been obvious to a person of ordinary skill in the art (POSITA) at the time the invention was made. The analysis is based on the prior art references cited in the patent's file wrapper.

The central inventive concept of the '103 patent appears to be the application of a specific geometric complexity, defined by "complexity factors" F21 and F32, to an antenna system within a multifunction wireless device (MFWD) that has either a multi-body structure (Claim 1), smartphone capabilities (Claim 15), or multimedia features (Claim 28). A successful obviousness argument would require combining prior art references that teach these elements and demonstrating a motivation to combine them.

Person of Ordinary Skill in the Art (POSITA)

A POSITA at the time of the invention (around the 2006 filing date) would be an electrical engineer or a physicist with a Bachelor's or Master's degree and several years of experience in radio frequency (RF) engineering and antenna design for portable wireless devices, such as mobile phones. This person would be familiar with various antenna types (e.g., PIFA, monopole), the challenges of designing multi-band antennas for compact devices, and the use of computer-aided design (CAD) and simulation tools for antenna optimization.

---

Analysis of Independent Claim 1

Claim 1: A multifunction wireless device having at least one of multimedia functionality and smartphone functionality, the multifunction wireless device including an upper body and a lower body, the upper body and the lower body being adapted to move relative to each other in at least one of a clamshell, a slide, and a twist manner; and an antenna system disposed within at least one of the upper body and the lower body and having a shape with a level of complexity of an antenna contour defined by complexity factors F21 having a value of at least 1.05 and not greater than 1.80 and F32 having a value of at least 1.10 and not greater than 1.90.

Primary Reference: U.S. Patent No. 7,015,874 B2 ("Samsung '874")

• Teaching: The Samsung '874 patent explicitly discloses an internal antenna for a "folder-type" (i.e., clamshell) mobile communication terminal. This directly teaches the core structural element of Claim 1: a wireless device with two bodies that move relative to each other. The patent also describes placing the antenna in either the main body or the folder (upper body), satisfying the "disposed within at least one of the upper body and the lower body" limitation. As a mobile phone of its era, it would inherently possess some multimedia or smartphone-like functionalities, such as messaging and a digital camera, which were becoming standard.

Secondary Reference: U.S. Patent No. 6,697,019 B2 ("Murata '019")

• Teaching: The Murata '019 patent teaches the design of compact, multi-band antennas for portable devices by using a "meandering conductor." The figures in the '019 patent show antenna elements with highly convoluted, space-filling shapes. The purpose of this meandering is to achieve miniaturization and multi-band performance by lengthening the electrical path of the antenna within a constrained area.

Combination and Motivation:

A person of ordinary skill in the art, when faced with the problem of designing a multi-band antenna for a compact, two-part device like the clamshell phone in Samsung '874, would be motivated to look for miniaturization techniques. The space available for an antenna in such a device is often limited and irregularly shaped, especially around the hinge mechanism.

The Samsung '874 patent itself acknowledges the need for wideband characteristics in a compact form factor. A POSITA would naturally turn to known techniques for achieving this, such as those described in the Murata '019 patent. The "meandering conductor" approach of Murata '019 is a well-understood method for creating a more complex, space-filling antenna structure to improve performance in a small volume.

Combining the teachings would be a matter of predictable design choice. The POSITA would start with the clamshell phone design from Samsung '874 and, to meet the multi-band and size requirements, would design the internal antenna using the meandering, convoluted geometry taught by Murata '019. This combination of a known device form factor with a known antenna miniaturization technique would lead to an antenna geometry with a high degree of complexity.

The Complexity Factors (F21 and F32): The final step is to assess whether this combination would lead to the specific F21 and F32 ranges claimed in the '103 patent. The '103 patent itself presents these factors as a way to characterize a complex antenna shape, not necessarily as a design input that was known in the art. An obviousness argument would posit that these factors are simply a new way of measuring the properties of an antenna that would inherently result from applying known design principles. By using the meandering techniques from Murata '019 to fit a multi-band antenna into the constrained space of the Samsung '874 device, a designer would likely and foreseeably arrive at a shape that, when measured by the '103 patent's new metric, would fall within the claimed F21 and F32 ranges. The ranges themselves (1.05-1.80 for F21 and 1.10-1.90 for F32) are broad and appear to encompass a wide variety of complex, space-filling antenna designs that result from standard optimization processes.

Therefore, it would have been obvious to a POSITA to implement a compact, multi-band antenna as taught by Murata '019 within the clamshell device taught by Samsung '874, resulting in a device that infringes Claim 1.

---

Analysis of Independent Claim 15

Claim 15: A multifunction wireless device having...a microprocessor and operating system adapted to permit running of word-processing, spreadsheet, and slide software applications, and at least one memory interoperably coupled to the microprocessor, the at least one memory having a total capacity of at least 1 GB...and an antenna system...[with the same F21 and F32 limitations as Claim 1].

Primary Reference Combination: The combination of Samsung '874 and Murata '019 as described above.

Additional Considerations:

This claim adds specific "smartphone" functionalities: an advanced operating system, the ability to run office-style applications, and at least 1 GB of memory. By the priority date of 2006, the concept of a "smartphone" was well-established. Devices running operating systems like Symbian, Windows Mobile, and Palm OS were common. These devices routinely offered capabilities for viewing and editing documents, and the inclusion of significant memory (1 GB was high-end but known) was a clear trend driven by consumer demand for more features and media storage.

The motivation to combine these features is simple market demand. As mobile phones evolved, integrating PDA and computer-like functionality was the primary direction of the industry. It would have been entirely obvious to a designer to take a modern phone form factor, such as the clamshell from Samsung '874, and equip it with the processing power, OS, and memory required for it to function as a smartphone.

The antenna design remains the key element. A smartphone with advanced data capabilities (requiring multi-band, high-speed connectivity) and a compact, often multi-body, form factor would present the exact same design challenges as discussed for Claim 1. The need for a small, efficient, multi-band antenna would be even more acute. Therefore, the motivation to use a space-filling, complex antenna geometry (as taught by Murata '019 and other references) would be even stronger.

Conclusion for Claim 15: The specific hardware and software features of a smartphone were well known in the art. Combining these features with a clamshell body (Samsung '874) and a compact, meandering antenna (Murata '019) would have been an obvious combination to meet market demands for powerful, small, and feature-rich mobile devices. The resulting antenna would likely possess the geometric complexity described by the F21 and F32 factors.

---

Analysis of Independent Claim 28

Claim 28: A multifunction wireless device having...a receiver of at least one of analog and digital sound signals, an image recording system comprising at least one of an image sensor having at least 2 Megapixels in size, a flash light, an optical zoom, and a digital zoom, and data storage means having a capacity of at least 1 GB...and an antenna system...[with the same F21 and F32 limitations as Claim 1].

Primary Reference Combination: The combination of Samsung '874 and Murata '019 as described above.

Additional Considerations:

This claim focuses on "multimedia" features. By 2006, the integration of high-quality cameras and music players into mobile phones was a dominant trend.

• 2 Megapixel Cameras & Flash: These were common features in mid-to-high-end phones.
• 1 GB Storage: This was necessary for storing music (MP3s) and high-resolution photos, and was available via internal memory or expansion cards (e.g., microSD).
• Sound Signal Receiver: This is a basic function of any radio-equipped device.

The motivation to combine these features is, again, market demand. Consumers expected their mobile phones to also serve as their primary portable camera and music player. A device designer would obviously integrate these popular multimedia features into a standard phone form factor, such as the clamshell from Samsung '874.

The inclusion of these components, particularly a camera module with a lens assembly and flash, would further constrain the internal volume available for the antenna, reinforcing the need for the miniaturization techniques taught by references like Murata '019. The designer would be forced to create an antenna that "snakes" around these other components, leading directly to a complex, non-rectangular contour.

Conclusion for Claim 28: It would have been obvious to a POSITA to design a mobile phone that combined the popular clamshell form factor of Samsung '874 with the multimedia features (high-resolution camera, large storage) that were standard in the market at the time. The physical constraints imposed by these additional components would motivate the use of a space-filling antenna design, as suggested by Murata '019, which would result in an antenna geometry falling within the F21 and F32 ranges defined in the claim.