PTAB

IPR2015-01596

Raritan Inc v. Server Technology Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electrical Power Distribution Device Having a Current Display
  • Brief Description: The ’771 patent relates to electrical power distribution units (PDUs) for use in data center equipment racks. The technology describes a PDU comprising an enclosure, power input and outputs, power control relays, a display for current-related information, and a system for reporting this information over a network.

3. Grounds for Unpatentability

Ground 1: Claims 1-14 are obvious over the MasterSwitch Vertical Mount (“MSVM”) Literature.

  • Prior Art Relied Upon: MSVM Literature (consisting of the MSVM User Guide, MSVM Quick Start manual, and MSVM PowerNet Guide, all published in 1999).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the MSVM Literature collectively discloses every element of independent claim 1. MSVM is a vertical-mount PDU with an enclosure, power input, multiple power outputs, and switched outlets controlled by relays. It includes an "Overcurrent alarm LED" that functions as the claimed "current-related information display," changing state to indicate normal, warning, and overload conditions. The MSVM product also featured a network-connectable current reporting system, either through a separate "MasterSwitch VM Controller" or via an integrated microcontroller and RJ-11 port, allowing for remote monitoring and management.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSA) would combine the teachings of the three MSVM documents because they all describe different aspects of the same commercially available product and were distributed together. A POSA would have viewed them as a single, collective teaching to understand the product's full functionality.
    • Expectation of Success: A POSA would have had a high expectation of success, as the combination merely involved reviewing the complete product documentation to understand the features of a single, existing device.

Ground 2: Claims 1-14 are anticipated by McNally.

  • Prior Art Relied Upon: McNally (Patent 6,741,442).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that McNally discloses every limitation of claims 1-14. McNally teaches a vertical "intelligent power strip" with an enclosure, an AC power source input, and multiple power outlets. The strip includes relays to switch certain outlets on and off, an overload LED display that changes color and flashes to indicate input current status, and internal power management circuitry. This circuitry, including a microcontroller and current sensor, constitutes the "current reporting system" and is connectable to a remote computer system for control and monitoring via communication ports. Petitioner argued this maps directly to all elements of claim 1, rendering it anticipated.

Ground 3: Claims 1-23 are obvious over Ewing in view of Wiebe and Lee.

  • Prior Art Relied Upon: Ewing (’974 patent), Wiebe (’494 patent), and Lee (’771 patent).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued this combination teaches all challenged claims. Ewing taught the core functional elements: "intelligent power modules" with relays for remote power control and a microprocessor-based system with "load sensors" for reporting current status over a network. Wiebe taught the structural elements: a vertical power strip enclosure with a power cord and outlets, explicitly designed for use in equipment racks. Lee taught the display element: a digital display on a PDU to show numerical current values to help prevent overloads.
    • Motivation to Combine: A POSA would combine these references to achieve a predictable result. It would have been obvious to package Ewing’s intelligent power management system within Wiebe’s known vertical rack-mount enclosure to create a product suitable for data centers. Further, a POSA would be motivated to replace a basic indicator light with Lee’s digital display to solve the known problem of current overload by providing more precise, actionable information to the user.
    • Expectation of Success: A POSA would have had a high expectation of success in combining these known elements, as it represented the simple substitution of one known element for another (a digital display for a simple LED) and the packaging of a known control system into a standard enclosure, both according to known methods.

  • Additional Grounds: Petitioner asserted additional challenges, including that claims 15-23 are obvious over MSVM Literature in view of Lee, claims 15-23 are obvious over McNally in view of Liu, and claims 1-23 are obvious over the BayTech RPC-7 Literature in view of Lee. These grounds primarily relied on adding a secondary reference (Lee or Liu) to a primary reference to teach the "digital" display required by claim 15.

4. Key Claim Construction Positions

  • "electrical power distribution device" / "enclosure": Petitioner argued that these terms should not be limited to requiring a "one-piece" or "fully integrated" device where all components are inside a single housing. Petitioner contended the plain language does not support this narrow construction, pointing out that element F only requires the reporting system to be "associated with" the enclosure. The presence of dependent claims reciting an "external power manager application" was cited as further evidence that the invention contemplates both internal and external components.
  • "current related information display": Petitioner asserted this term (from claim 1) should be interpreted broadly to include any visual indicator of current, such as a single LED. Petitioner argued that construing it to require a numerical or graphical display would be improper, as it would render the distinct limitation "digital current information display" in independent claim 15 superfluous, violating the doctrine of claim differentiation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-23 of the ’771 patent as unpatentable.