PTAB

IPR2016-00658

Fitbit Inc v. AliPHCom Inc

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1. Case Identification

2. Patent Overview

  • Title: Power Management for a Wearable Data-Capable Band
  • Brief Description: The ’522 patent discloses structures and techniques for managing power consumption in a wearable, data-capable band. The invention focuses on a power management system that places the device in a low-power "shipping mode" and transitions it to a normal operational mode upon the application of external power.

3. Grounds for Unpatentability

Ground 1: Claim 2 is obvious over James in view of Chou.

  • Prior Art Relied Upon: James (Application # 2009/0076343) and Chou (Application # 2009/0264714).
  • Core Argument for this Ground: Petitioner argued that the combination of James and Chou teaches every limitation of claim 2. Critically, Petitioner emphasized that during prosecution of a related, co-pending application, a different USPTO examiner rejected claims substantially identical to claim 2 as obvious over this same combination of James and Chou. Petitioner asserted that the Patent Owner never disclosed these references or the rejection to the examiner of the ’522 patent.
    • Prior Art Mapping: Petitioner asserted that James, which teaches an adherent patch device for monitoring physiological parameters, discloses nearly all functional elements of claim 2. This includes a subset of sensors, a controller, an energy storage device, and a comprehensive power manager. James’s power manager teaches a "storage mode" (first power mode) where sensors are inactive to prevent battery drain, deactivating selected sensors, and modulating clock speed to optimize energy. James also teaches transitioning from this storage mode to an active mode (second power mode) upon activation, such as detecting a connection to external electronics. Chou was cited for teaching the implementation of a physiological monitoring device in the form of a wearable "band" or "belt" for user comfort and convenience.
    • Motivation to Combine: A POSITA would combine the power management system of James’s patch with the wearable band form factor of Chou to improve user comfort, convenience, and mobility. Petitioner noted that Chou explicitly teaches that a patch configuration "can be directly integrated with the belt," providing a clear motivation for the combination.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as it involved incorporating known power-saving features into a well-known wearable form factor to achieve the predictable result of a power-efficient, user-friendly device.

Ground 2: Claim 2 is obvious over Tan in view of Tanaka.

  • Prior Art Relied Upon: Tan (Application # 2009/0326406) and Tanaka (Japanese Patent No. 4,146,539B2).
  • Core Argument for this Ground: Petitioner argued that Tan discloses a wearable electronic band with most of the claimed hardware and some power-saving features, while Tanaka provides the specific teachings of a low-power "shipping mode" that is cancelled upon connection to a charging circuit, directly mapping to the novel aspects of claim 2.
    • Prior Art Mapping: Tan was argued to teach a wearable band (e.g., armband, wristwatch) with sensors, a controller, a battery, and a USB connector for power and data. Tan further teaches the importance of conserving battery power and discloses disabling unused sensors to do so. Tanaka was cited for teaching a low-power consumption mode specifically for use during shipping to preserve the battery. Tanaka explicitly discloses that this shipping mode (first power mode) is cancelled and the device is switched to a higher-power operational mode (second power mode) upon detection that the device is connected to a charging circuit. Tanaka also teaches modulating clock frequency as a power-saving technique.
    • Motivation to Combine: A POSITA would have been motivated to apply the known, general-purpose battery-saving shipping technique from Tanaka to the specific wearable electronic device in Tan. Since Tan’s device has a rechargeable battery, a POSITA would recognize that it would be manufactured and shipped to users, and would benefit from Tanaka’s technique to predictably improve battery life during that shipping interval.
    • Expectation of Success: The combination would have yielded predictable results, as it constituted the application of a known technique (a shipping mode) to a known device (a wearable band) to solve a known problem (battery drain before first use).

Ground 3: Claim 2 is obvious over Yasukawa in view of Tanaka.

  • Prior Art Relied Upon: Yasukawa (Patent 5,795,301) and Tanaka (Japanese Patent No. 4,146,539B2).
  • Core Argument for this Ground: Petitioner contended that while the examiner of the ’522 patent found that Yasukawa taught most limitations of the original claims, the examiner did not have the benefit of Tanaka. Tanaka, Petitioner argued, supplies the key "shipping mode" limitation that formed the basis for the allowance of claim 2.
    • Prior Art Mapping: Yasukawa was presented as teaching a wrist-worn portable pulse measuring device that includes a band, sensors, a controller, a battery, and a connector for power and control signals. Yasukawa also teaches a mode-switching unit for power management, including a "clock mode" (first power mode) where the sensor unit is powered down to conserve energy, and a "pulse measuring mode" (second power mode) where the sensors are powered on. Tanaka was again relied upon for its teaching of a specific low-power shipping mode that is cancelled upon connection to a charger, corresponding to the claimed first interval of time (shipping) and second interval of time (operation).
    • Motivation to Combine: The motivation was identical to that in Ground 2. A POSITA would apply Tanaka's general-purpose shipping mode to Yasukawa's battery-operated, wrist-worn device to predictably conserve battery life between manufacturing and first use.
    • Expectation of Success: A POSITA would expect success in implementing Tanaka's low-power shipping mode into Yasukawa's device, as it was a known technique for improving battery life in electronic devices and would predictably achieve that result.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 2 of the ’522 patent as unpatentable.