Obviousness

Obviousness Analysis under 35 U.S.C. § 103

This section analyzes the obviousness of US Patent 9,198,261 by identifying combinations of prior art references that would render its claims obvious to a person having ordinary skill in the art (PHOSITA). The analysis considers the motivations a PHOSITA would have to combine these references. The critical date for prior art is the priority date of US 9,198,261, which is September 3, 2010.

Legal Standard for Obviousness

Under 35 U.S.C. § 103, an invention is obvious if "the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains." This analysis considers four factors, as established in Graham v. John Deere Co.: (1) the scope and content of the prior art; (2) the differences between the prior art and the claims at issue; (3) the level of ordinary skill in the pertinent art; and (4) secondary considerations of non-obviousness. A combination of prior art references is obvious if there was an apparent reason to combine them, such as to achieve a predictable result, to combine references that work together, or to use a known technique to improve a similar device in the same way.

Level of Ordinary Skill in the Art

A person of ordinary skill in the art for this patent would likely have a bachelor's degree in electrical engineering or a related field, along with several years of experience in designing and developing electronic devices, particularly those involving sensors, power management, and illumination for portable applications.

Prior Art References

The patent US 9,198,261 itself cites the following prior art reference in its background:

• DE 20 2007 011 357 U1 (Schech): This German utility model describes an illumination device placed in an object that cannot be opened, where the light source is activated by motion or touching. The patent notes that a disadvantage of this device is inadvertent activation when placed in a purse, leading to fast discharge of the energy storage.

Additionally, the patent lists several other cited prior art documents, which are relevant for an obviousness analysis:

• US 5,018,057 A (Lamp Technologies, Inc.): "Touch initiated light module".
• WO 2002/000056 A1 (Voggenberger): "Device for illuminating the inside area of an openable container".
• DE 100 63 370 A1 (Schaffer Herbert): "Bag or carrying case has internal energy source and illumination device for easy visibility of bag or case contents".
• US 2005/0002181 A1 (Chernick): "Illuminated cosmetic case structure".
• US 2005/0057923 A1 (Big Bang Industries, Llc): "Method and apparatus to illuminate the interior of a fashion accessory".
• US 2005/0135083 A1 (Tait): "Purse illumination assembly".
• US 2008/0198585 A1 (Tait): "Purse illumination assembly".
• US 2011/0188229 A1 (Hernandez): "Electronic device for receptacles, activated by reed switch and magneto, of hall or inclination effect, for emission of luminous and/or auditory signals".

Obviousness Combinations

Independent Claim 1

Independent Claim 1 describes an illuminating device with a first light source activated by a first sensor (touch/motion), a second sensor that detects if the object is open or closed, and a second switching unit that supplies power to the first and/or second light source when the object is open. Critically, the claim specifies that the first light source is functionally assigned to the first sensor, the second light source to the second sensor, and the control unit is designed such that the first switching unit transfers from closed to open (turning off the first light source) if the second switching unit transfers from open to closed (turning on the second light source).

Combination 1: DE 20 2007 011 357 U1 + WO 2002/000056 A1 + US 2005/0057923 A1

• DE 20 2007 011 357 U1 discloses a lighting device activated by motion or touch, but it is placed in an object that cannot be opened, and suffers from inadvertent activation.
• WO 2002/000056 A1 teaches a device for illuminating the inside of an openable container, implying a sensor to detect the open/closed state of the container.
• US 2005/0057923 A1 (Big Bang Industries) describes methods and apparatus to illuminate the interior of a fashion accessory, which would include mechanisms for activation and deactivation.

Motivation for combination: A PHOSITA, seeking to overcome the problem of inadvertent activation and energy drain identified in DE '357 (which only has motion/touch activation and is in an object that cannot be opened), would be motivated to combine it with a system that detects the opening of a container, as taught by WO '056. The aim would be to provide more intelligent control over the illumination. Furthermore, integrating the internal lighting functionality from US '923 into an openable container with dual activation logic (motion/touch for external visibility, open-state for internal illumination) would be a logical step for improving usability and energy efficiency for a device in a purse or similar object. The specific arrangement of turning off the first light when the second is activated would be an obvious choice for a PHOSITA focused on power saving in a battery-operated portable device. The functional assignment of sensors to respective light sources is a straightforward design choice to achieve the desired behavior.

Independent Claim 9

Independent Claim 9 combines the illuminating device with an object forming two dome-shaped parts, where the first sensor is a capacitive sensor.

Combination 2: US 2005/0057923 A1 + US 5,018,057 A + US 2005/0002181 A1

• US 2005/0057923 A1 describes illuminating the interior of a fashion accessory, which could certainly include objects with dome-shaped parts (e.g., compacts).
• US 5,018,057 A explicitly teaches a "Touch initiated light module," which is a broad category that would encompass capacitive sensors as a known technology for touch detection at the priority date of US '261. Capacitive sensors were a well-established technology for touch and proximity sensing by 2010.
• US 2005/0002181 A1 (Chernick) specifically discloses an "Illuminated cosmetic case structure," which is often formed with two hinged, clam-shell or dome-shaped parts.

Motivation for combination: A PHOSITA would be motivated to integrate a capacitive sensor (known from US '057 for touch-initiated lighting) into an illuminated cosmetic case (from US '181) to provide touch-based activation. The use of dome-shaped parts for a cosmetic case is explicitly shown in US '181. Therefore, combining an illuminated cosmetic case with a capacitive touch sensor for activation would be an obvious design choice for improved user interaction.

Independent Claim 19

Independent Claim 19 claims an illuminating device with a first light source, electric energy storage, a switch device with a control unit and capacitive sensor (first sensor) for touch/motion detection, and a dimmer actuatable by the control unit to reduce power to the first light source.

Combination 3: DE 20 2007 011 357 U1 + US 5,018,057 A + DE 100 63 370 A1 (or US 2005/0057923 A1)

• DE 20 2007 011 357 U1 provides the basic illuminating device with a light source, energy storage, and motion/touch activation.
• US 5,018,057 A teaches a "Touch initiated light module", which implies a control mechanism for the light. As noted previously, a capacitive sensor would be a known equivalent for touch detection.
• DE 100 63 370 A1 discloses a "Bag or carrying case has internal energy source and illumination device for easy visibility of bag or case contents", reinforcing the concept of portable illumination with its own power.
• Alternatively, US 2005/0057923 A1 broadly discusses illuminating fashion accessories.

Motivation for combination: A PHOSITA would be motivated to take the motion/touch activated illumination device of DE '357, replace the generic touch/motion sensor with a capacitive sensor (a known alternative from US '057 for touch activation), and add a dimmer. Dimmers are a common feature in lighting control to manage brightness and save power, especially in battery-operated devices (like those in DE '370 or US '923). The ability to gradually or abruptly reduce light to zero is a standard function of a dimmer. Integrating a dimmer into a portable, sensor-activated light for power efficiency and user preference would be an obvious design choice in the art.