PTAB

IPR2015-01879

Apple Inc v. Comarco Wireless Technologies Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Power Supply Equipment with Data Signal for Electronic Device
  • Brief Description: The ’933 patent describes power supply equipment for electronic devices. The system features an adapter that provides DC power and communicates with the electronic device via a data signal to control power draw and a separate data output to identify the power supply's characteristics.

3. Grounds for Unpatentability

Ground 1: Obviousness over Allen - Claims 1 and 2 are obvious over Allen in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Allen (Patent 7,243,246).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Allen taught a power adapter system that met most limitations of claim 1. Allen disclosed a power adapter (12) that converts power for an electronic device, connected by a cable (18) with multiple conductors (DC lines 38, ID signal 42). Allen’s adapter included identification circuits (77, 78) that produced a "data signal" on line 42, which the device used for power management, thereby controlling the power drawn. Petitioner contended that a POSITA would understand Allen's generic "data signal" to encompass either an analog or digital signal, making the choice of an analog signal an obvious design option. For limitation 1e (circuitry to receive a request and transmit a response), Petitioner argued that Allen's disclosure of an electronic device "pinging" the adapter's identification chip met this limitation. Alternatively, it would be obvious to configure Allen's system for request-response using the off-the-shelf Dallas Semiconductor (DS2501) circuits that Allen explicitly discloses.
    • Motivation to Combine: The primary motivation was to implement Allen's teachings using predictable, well-known design choices. A POSITA would have found it obvious to use an analog signal, as it was one of only two known options and could be simpler to implement. Similarly, placing the identification circuitry in the output connector was argued to be a commonsense design choice, as the ’933 patent itself acknowledges such configurations as prior art.
    • Expectation of Success: A POSITA would have a high expectation of success, as implementing a data signal with analog circuitry and positioning components within a connector were routine and well-understood engineering tasks.

Ground 2: Obviousness over Allen, Breen, and Castleman - Claims 1 and 2 are obvious over Allen in combination with Breen and Castleman.

  • Prior Art Relied Upon: Allen (Patent 7,243,246), Breen (Patent 7,296,164), and Castleman (Patent 6,054,846).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground strengthened Ground 1 by using references that Petitioner argued explicitly taught what Allen only implicitly disclosed or rendered obvious. Allen provided the foundational power adapter system. Breen was introduced to explicitly teach the request-response functionality of limitation 1e. Breen described a "PSID" line that allowed a controller in the electronic device to send a request signal to power peripherals and receive identification information in response. Castleman was introduced to explicitly teach placing the identification circuitry within the output connector at the distal end of the cable, disclosing a memory chip (132j) housed in the output connector (138j).
    • Motivation to Combine: A POSITA would combine Allen and Breen because both patents were assigned to the same entity (Dell Products L.P.), addressed the identical problem of mismatched power supplies, and used similar data-line architectures. Breen's request-response system offered a more power-efficient solution than a constant broadcast, providing a clear motivation for its inclusion. A POSITA would combine Allen with Castleman because Castleman addressed the same subject matter and provided an express motivation—cost benefits and compact component size—for placing identification circuitry within a cable's output connector.
    • Expectation of Success: Success was predictable, as the combination involved integrating known, compatible features to achieve their respective, well-understood benefits in a single system.

Ground 3: Obviousness over Veselic and Thomas - Claims 1 and 2 are obvious over Veselic in combination with Thomas.

  • Prior Art Relied Upon: Veselic (European Application Publication EP 1487081) and Thomas (Patent 5,649,001).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a different technological approach based on the USB standard. Petitioner argued Veselic disclosed a USB charger that converted AC/DC power and used the standard USB data lines (D+, D-) to transmit a "charger configuration signal" to a mobile device. This signal, which could be continuously variable in frequency and duty cycle, was asserted to be an analog data signal used by the device to determine the charger's maximum current and control power draw. The combination with Thomas was proposed to explicitly teach the request-response functionality. Thomas disclosed communication adapter cables with embedded circuitry that provided an identification code in response to a query from a connected device, and taught that this circuitry could be located in the cable's connector.
    • Motivation to Combine: A POSITA would combine these references to enhance Veselic's USB-based charging system. Veselic's goal was to merge power and data communications over a standard interface (USB). Thomas taught a known technique for device identification and configuration in communication cables. A POSITA would be motivated to apply Thomas's established request-response identification method to Veselic's system to create a more robust and interactive power delivery standard over USB, a common communication platform.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Thomas stated its adapter cable technique was applicable to various communication networks. Recognizing USB as such a network, a POSITA would find it straightforward to apply Thomas's teachings to Veselic's USB-based system.

4. Key Claim Construction Positions

  • "proximal and distal ends," "proximal end," "distal end": Petitioner proposed these terms should be construed relative to the adapter, meaning "an end situated nearer to the adapter" and "an end situated away from the adapter," respectively.
  • "output connector": Petitioner proposed this term be construed as a "mechanical assembly for electrically coupling the cable in an electrical circuit," distinguishing it from a permanent, hard-wired connection.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1 and 2 of the ’933 patent as unpatentable.