PTAB

IPR2014-00529

Kinetic Technologies Inc v. Skyworks Solutions Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Integrated Circuit Device with Serial Interface and Method of Operation
  • Brief Description: The ’320 patent describes an integrated circuit (IC) device that uses a serial interface to receive signal pulses. A counter within the IC counts these pulses, and the resulting count is used to set a specific operating mode or control state for the device.

3. Grounds for Unpatentability

Ground 1: Claims 13-24 and 37-47 are obvious over Loke in view of Adlhoch and Enomoto.

  • Prior Art Relied Upon: Loke (Application # 2002/0039891), Adlhoch (Patent 3,387,270), and Enomoto (Patent 5,277,497).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Loke, discloses the core of the invention claimed in independent claims 13 and 37. Loke teaches a power integrated circuit with a single input, a core circuit, and an interface for controlling it. This interface includes a pulse counter (a "first circuit") that accumulates a count of clock pulses from a received signal and a look-up table (a "second circuit") that maps the final pulse count to a control state for the core circuit.
    • However, Petitioner contended that Loke does not explicitly teach two key features: a "third circuit" for resetting the pulse count and the progressive mapping of count values to intermediate control states.
    • To supply the missing reset functionality, Petitioner relied on Adlhoch. Adlhoch teaches an "inter-digit timer" that resets a pulse counter if the interval between pulses exceeds a predetermined timeout value (i.e., the signal is low for too long). Petitioner argued that a person of ordinary skill in the art (POSITA) would integrate Adlhoch’s timer into Loke's circuit to serve as the claimed "third circuit for resetting the count."
    • To supply the progressive mapping feature, Petitioner relied on Enomoto. Enomoto teaches a counter that outputs progressively increasing count values as pulses are accumulated. Its D/A converter then progressively maps each of these intermediate count values to a corresponding output, such as to control the brightness of an LED. Petitioner argued it would be obvious to modify Loke’s counter and mapping circuit to incorporate Enomoto’s progressive counting and mapping capabilities.
    • For the dependent claims, Petitioner argued that Loke and Enomoto variously disclose the additional limitations, such as using a Read Only Memory (ROM) for the look-up table (Loke), using an array of logic elements for mapping (Enomoto), maintaining a count while the signal is high (Enomoto), and applying the technology to an LED current source (Enomoto).
    • Motivation to Combine: Petitioner asserted several motivations for the combination. A POSITA would combine Loke and Adlhoch because Loke itself suggests that signaling schemes other than its disclosed Pulse Duration Modulation (PDM) could be used. Adlhoch teaches an alternative scheme based on bursts of pulses, and implementing such a scheme would require a reset mechanism like Adlhoch’s timer to distinguish between bursts. The combination was presented as a predictable substitution of known signaling techniques. The motivation to combine this modified Loke/Adlhoch system with Enomoto arose from the desire for finer control over a device's operation. A POSITA would combine the known elements from Loke and Enomoto (both of which use counters and D/A converters) to achieve the predictable result of mapping intermediate pulse counts to intermediate control states, a common goal in applications like adjusting LED luminosity.
    • Expectation of Success: Petitioner argued that a POSITA would have a reasonable expectation of success because the combination involves nothing more than applying known electronic principles and combining well-understood circuit blocks (counters, timers, look-up tables, D/A converters) to achieve their predictable functions.

4. Key Claim Construction Positions

  • "receiving a signal via a single input": Petitioner argued this term, added during prosecution to overcome prior art, requires a specific construction. Based on the prosecution history, Petitioner contended the phrase should be construed as "receiving a signal encoded with clock pulses, which signal is the same signal encoding a low period that exceeds a predetermined timeout value." This construction means the same physical input line must carry both the clock pulses for counting and the low-level signal for resetting the counter. This interpretation was central to Petitioner's argument that the combined Loke/Adlhoch system meets the "single input" limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 13-24 and 37-47 of the ’320 patent as unpatentable under 35 U.S.C. §103.