PTAB
IPR2014-00964
LG Electronics Inc v. NFC Technology LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2014-00964
- Patent #: 7,665,664
- Filed: June 16, 2014
- Petitioner(s): LG Electronics, Inc., LG Electronics USA, Inc., and LG Electronics Mobilecomm U.S.A., Inc.
- Challenged Claims: 13 and 29
2. Patent Overview
- Title: Inductive Coupling Reader Comprising Means for Extracting a Power Supply Voltage
- Brief Description: The ’664 patent relates to an inductive coupling reader for Near Field Communication (NFC) that is capable of operating in both an active mode, using an internal power source, and a passive mode. In the passive operating mode, the reader uses an auxiliary supply circuit to extract and use power from an external magnetic field.
3. Grounds for Unpatentability
Ground 1: Anticipation - Claims 13 and 29 are anticipated by Akiho under 35 U.S.C. §102.
- Prior Art Relied Upon: Akiho (Patent 7,261,240).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Akiho, which teaches a portable telephone with RFID functionality, discloses every limitation of the challenged claims. Akiho describes a device capable of switching between an active "reader/writer" mode and a passive "non-contact IC card" mode. In the active mode, it uses internal battery power to transmit data. In the passive mode, it uses a regulator and rectifying circuit—which Petitioner asserted constitutes the claimed "auxiliary supply circuit"—to take energy from a received magnetic field and convert it into a DC voltage to power the device's non-contact IC card circuit. This dual-mode operation and power extraction capability allegedly meets all limitations of independent claim 13. For dependent claim 29, Petitioner argued Akiho’s disclosure of a portable telephone with a processor and rechargeable battery meets the additional limitations.
Ground 2: Anticipation - Claims 13 and 29 are anticipated by Amtmann under 35 U.S.C. §102.
- Prior Art Relied Upon: Amtmann (Patent 7,603,090).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Amtmann, directed to an NFC device that can operate in both "active send" and "passive send" modes, also anticipates all claim limitations. In active mode, Amtmann’s device uses an internal power source (e.g., a battery) to generate and modulate a carrier signal. In passive mode, it uses a "voltage supply stage" to extract energy from a signal received from another device. Petitioner asserted this voltage supply stage is the claimed "auxiliary supply circuit coupled to the antenna circuit." For claim 29, Petitioner argued Amtmann’s description of a portable device like a cell phone with processing components (e.g., sequence control stage) and a battery meets the claim’s requirements.
Ground 3: Obviousness over Amtmann and ECMA-340 - Claims 13 and 29 are obvious over Amtmann in view of ECMA-340.
- Prior Art Relied Upon: Amtmann (Patent 7,603,090) and ECMA-340 ("Standard ECMA-340 – Near Field Communication Interface and Protocol (NFCIP-1)," Dec. 2002).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued this combination renders the claims obvious, presented as an alternative to the anticipation argument against Amtmann alone. Amtmann teaches all elements of the claims, but explicitly references the ECMA-340 NFC standard for its operation. The ECMA-340 standard explicitly defines the "working frequency" for NFC communication as 13.56 MHz, thereby supplying any potential deficiency in Amtmann’s disclosure of this limitation.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) implementing the NFC device in Amtmann would be directly motivated to consult the ECMA-340 standard that Amtmann itself references. This consultation would be necessary to determine key operating parameters, like the carrier frequency, to ensure interoperability with other NFC devices.
- Expectation of Success: A POSITA would have a high expectation of success, as using the standard-defined frequency is the intended and necessary method for creating a functional and compatible device.
Ground 4: Obviousness over Charrat and Kuhl - Claims 13 and 29 are obvious over Charrat in view of Kuhl.
- Prior Art Relied Upon: Charrat (Application # 2003/0169152) and Kuhl (Patent 8,384,519).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Charrat, a reference considered during prosecution (and sharing an inventor with the ’664 patent), discloses a dual-mode reader with every claimed feature except for the auxiliary supply circuit being configured to power the reader. Petitioner asserted that Kuhl, which was not before the Examiner, remedies this deficiency by teaching an RFID reader that includes an auxiliary supply circuit specifically for extracting power from a received electromagnetic field.
- Motivation to Combine: A POSITA would combine Kuhl’s teachings with Charrat’s reader to solve a known problem. Kuhl explicitly addresses the limitations of readers that rely solely on internal power (like Charrat's), which may be unavailable (e.g., dead battery) or prohibited (e.g., in hospitals or airports). Kuhl’s solution—extracting power from an external field—provides a clear benefit of improved reliability and functionality that a POSITA would have been motivated to incorporate into the Charrat reader.
- Expectation of Success: The combination would have been a predictable and straightforward application of a known solution (Kuhl's power circuit) to a known device type (Charrat's reader) to achieve a known benefit.
4. Key Claim Construction Positions
- "Active Operating Mode": Petitioner proposed this term be construed to mean an operating mode that uses power from a power source that is internal to the device, such as a battery.
- "Passive Operating Mode": Petitioner proposed this term be construed to mean an operating mode that uses power extracted from an electromagnetic field received from an external device.
5. Relief Requested
- Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 13 and 29 of the ’664 patent as unpatentable on all asserted grounds.
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