PTAB

IPR2015-01083

Dell Inc v. NXP BV

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of Powering-Up Battery Powered Apparatus
  • Brief Description: The ’365 patent relates to a method for powering up battery-powered equipment using a phased activation of a load. This incremental power-up process is designed to avoid excessive transitory drops in the battery's supply voltage that can occur when a full load is applied instantaneously, preventing unexpected resets or other problems.

3. Grounds for Unpatentability

Ground 1: Claims 3, 6, 8, and 10-14 are obvious over Nagai in view of Taguchi.

  • Prior Art Relied Upon: Nagai (Japanese Patent Application Disclosure No. P2000-287371) and Taguchi (Patent 5,659,206).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nagai taught the core concept of the ’365 patent: powering up a battery-powered device by activating a plurality of load circuits successively rather than simultaneously to mitigate transient voltage fluctuations. This successive activation at "mutually different timings" corresponds to the "phased activation" limitation. Dependent claims requiring voltage monitoring and subsequent load increases after voltage recovery were not fully met by Nagai, which used predetermined time intervals. Taguchi, however, was argued to supply this missing element by disclosing a voltage detector that monitors battery voltage and activates a load only after the voltage has recovered to a predetermined level.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Nagai and Taguchi because both references address the same problem of reducing transient voltage fluctuations during power-up. Petitioner asserted it would have been an obvious improvement to modify Nagai’s system, which relies on fixed, predetermined time intervals between load stages, with Taguchi’s more efficient real-time voltage monitoring. This modification would allow the device to start up more efficiently by basing the timing of subsequent load increments on actual voltage recovery rather than conservative estimates.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involved applying a known technique (real-time voltage monitoring for load switching) to improve a similar device (a staged power-up circuit) to achieve a predictable result.

Ground 2: Claims 3, 6, 8, and 10-14 are obvious over Herrell in view of Taguchi.

  • Prior Art Relied Upon: Herrell (Patent 5,963,023) and Taguchi (Patent 5,659,206).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented this ground as an alternative, noting that Herrell discloses a different form of "phased activation." Instead of activating separate load circuits, Herrell taught incrementally increasing a parameter of a single load (the operating frequency of a microprocessor) in stages during power-up. This "staged increase in operating frequency" was argued to reduce current surges and limit voltage sag, thereby meeting the limitations for a "phased activation" that occurs within a single load. Similar to the Nagai combination, Herrell used fixed time intervals for the frequency steps. Petitioner argued that Taguchi’s disclosure of monitoring for voltage recovery before activating a load would render the dependent claims obvious.
    • Motivation to Combine: The motivation was analogous to Ground 1. A POSITA would be motivated to improve Herrell's system by replacing its use of fixed time delays with Taguchi's real-time voltage monitoring. This would allow the microprocessor's operating frequency to be stepped up as soon as the supply voltage stabilized, optimizing the power-up sequence and reducing unnecessary delays. Petitioner noted this ground was particularly relevant if the patent claims were construed as being limited to a single load, an argument the patent owner made during original prosecution.
    • Expectation of Success: The combination of Herrell's staged frequency increase with Taguchi's voltage monitoring was argued to be a predictable application of known design principles to achieve improved performance.

  • Additional Grounds: Petitioner asserted a third ground that claims 3, 6, 8, and 10-14 are obvious over Nagai in view of Taguchi and further in view of Herrell. This ground was presented to the extent the primary combinations were found to be insufficient.

4. Key Claim Construction Positions

  • "phased activation": Petitioner proposed this term be construed as "a succession of incremental increases during power-up." This construction was argued to be broad enough to encompass both the successive power-up of multiple loads (as in Nagai) and the incremental increase of a parameter within a single load (as in Herrell).
  • "function": Petitioner proposed construing this term as "a current drawing load capable of powering-up in stages."
  • Means-Plus-Function Limitations: Petitioner argued that several means-plus-function limitations in claims 8 and 12-14 correspond to a "microcontroller or an equivalent thereof" as the structure disclosed in the ’365 patent specification. This construction was critical to the invalidity arguments, as Petitioner contended that the "voltage detection circuit" in Nagai and the "feedback control circuitry" in Herrell were either microcontrollers or equivalents thereof that performed the identical claimed functions in substantially the same way to achieve the same result.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 3, 6, 8, and 10-14 of the ’365 patent as unpatentable.