PTAB

IPR2015-00908

AVX Corp v. Greatbatch Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Feedthrough Filter Capacitor Assembly with Internally Grounded Hermetic Insulator
  • Brief Description: The ’076 patent relates to an internally grounded, feedthrough filter capacitor assembly for use in implantable medical devices like pacemakers. The technology aims to provide a cost-effective and size-efficient solution for shielding against electromagnetic interference (EMI) by using a hermetic insulator that includes an internal ground plate, which is conductively coupled to a ferrule, thereby grounding the capacitor without requiring an external connection to the capacitor's outer surface.

3. Grounds for Unpatentability

Ground 1: Anticipation by Stevenson - Claims 1-9, 11-22, 24-34, and 36-38 are anticipated by Stevenson.

  • Prior Art Relied Upon: Stevenson (Patent 7,038,900).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stevenson, a patent commonly assigned to the Patent Owner but not cited during prosecution, discloses every limitation of the challenged claims. Stevenson allegedly teaches an internally grounded feedthrough filter capacitor assembly (FIGS. 71-74) comprising a capacitor (810) and a multi-layer insulator (1040). Petitioner asserted that Stevenson’s insulator contains internal ground plates or traces (346) and features separate passageways for a terminal pin (136) and a ground pin (236). The ground pin (236) extends through the insulator to connect with the internal ground plates (346) and also extends through the capacitor to connect with the second set of electrode plates (320). Critically, this structure conductively couples the capacitor’s ground plates to the assembly’s ferrule (122) via the insulator's internal ground plates, mirroring the core architecture of the ’076 patent’s claims.

Ground 2: Anticipation/Obviousness over Brendel and Wolf - Claims 1, 5, 6, and 11-15 are anticipated by Brendel or, alternatively, obvious over Brendel in view of Wolf.

  • Prior Art Relied Upon: Brendel (Patent 6,529,103) and Wolf (Patent 6,414,835).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Brendel discloses an internally grounded capacitor assembly that meets most claim limitations, including a capacitor (410), an insulator (406), a terminal pin (402), a ferrule (404), and a ground pin (420). Brendel’s insulator includes a deposited ground plane (430) that couples the ground pin to the ferrule. However, Petitioner characterized Brendel's ground plane as having a complex, "tortuous profile" that is difficult to manufacture. The alternative obviousness argument posits that if Brendel’s ground plane is not considered a "ground plate" under the claim construction, then the claims are obvious over Brendel in view of Wolf. Wolf discloses a feedthrough filter capacitor with an insulator having simple, flat, and easily manufacturable ground plates (132, 134, 136).
    • Motivation to Combine (for §103 ground): A person of ordinary skill in the art (POSA) would combine the teachings by substituting Wolf’s simple, flat ground plates for Brendel’s complex, tortuous ground plane. The motivation would be to simplify the manufacturing process, reduce complexity, and lower costs by replacing a known component with a known, functionally equivalent, and more efficient alternative.
    • Expectation of Success (for §103 ground): A POSA would have a reasonable expectation of success because substituting one type of internal grounding structure (Brendel's) for another (Wolf's) was a predictable design choice, as both perform the identical function of creating a conductive path to ground.
  • Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges against claims 2-4, 16-19, 24-28, and 29-38 based on the Brendel and Wolf combination. These grounds relied on the same core substitution theory, applying it to the specific limitations of the remaining independent and dependent claims. For example, independent claim 16, which recites a "conductive material" instead of a "means for...coupling," was argued to be met by Brendel's ground pin (420). Independent claim 29, which adds a ground plate extending to the insulator's outer surface, was argued to be met by Brendel's ground plane (430) or the combination with Wolf.

4. Key Claim Construction Positions

  • "means for conductively coupling the capacitor second set of electrode plates and the insulator ground plate" (Claim 1): Petitioner argued this term is a means-plus-function limitation under 35 U.S.C. § 112, para. 6 (pre-AIA). The petition identified the corresponding structure disclosed in the ’076 patent's specification as: "Conductive material extending into a second passageway of the capacitor...and into a passageway of the insulator... The conductive material may comprise one or more ground pins, a ground wire, a solder material, a conductive thermosetting material, a weld, a braze, a conductive glass, or a conductive spring coil." This construction was central to the argument that the prior art, which discloses conductive ground pins performing this exact function, anticipates or renders the claims obvious.
  • "ground plate" (Claims 1, 16, 29, etc.): Petitioner proposed construing this term as "a thin layer by which electrical signals may be transmitted to ground." This broad construction was intended to encompass the flat plates in Wolf as well as the traces disclosed in Stevenson.
  • "conductively coupled": Petitioner proposed this term be construed as "coupled in a way that permits transmission of electrical signals," noting that direct physical contact is not required and conductive mediums like solder are contemplated.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9, 11-22, 24-34, and 36-38 of the ’076 patent as unpatentable.