PTAB

IPR2016-00684

NXP Semiconductors USA Inc v. NFC Technology LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Contactless Integrated Circuit Reader
  • Brief Description: The ’770 patent discloses methods and systems for two contactless integrated circuit readers to exchange data via inductive coupling. The invention purports to overcome the cost of networked terminals or the tediousness of manual connections by enabling one reader to operate in a mode that simulates a contactless integrated circuit (CIC), allowing it to communicate directly with a second reader.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ritter and RFID Handbook - Claims 13-15, 18-20, 23-25, 36, 37, 40, 42, 43, and 46 are obvious over Ritter in view of the RFID Handbook.

  • Prior Art Relied Upon: Ritter (International Publication No. WO 98/58510) and the RFID Handbook (English version "RH-E" or German version "RH-G").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ritter taught the core inventive concept: a mobile device with a two-way inductive interface capable of operating in two modes. In the first mode, it acted as a standard reader, powering and communicating with another device. In the second mode, it was inductively powered by the other device and acted as a transponder (simulating a CIC). Ritter explicitly disclosed that two such mobile devices could communicate with each other to exchange data. Petitioner contended that the RFID Handbook, a seminal text on radio-frequency identification fundamentals, provided all the remaining, well-known implementation details recited in the claims, such as the use of specific circuits (antenna, excitation, extraction), modulation techniques (e.g., Amplitude-Shift Keying), and data transfer principles (e.g., load modulation) common to any standard RFID system.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) seeking to build the dual-mode communication system described in Ritter would naturally and obviously turn to a standard reference like the RFID Handbook to implement the system using conventional, well-understood RFID components and processes. This combination represented the application of known techniques to a known problem to yield predictable results.
    • Expectation of Success: As the RFID Handbook detailed the fundamental building blocks of RFID systems, a POSITA would have had a high expectation of success in using its teachings to implement the specific dual-mode reader-to-reader system disclosed by Ritter.

Ground 2: Obviousness over Ritter, RFID Handbook, and Vega - Claims 14, 15, 23-25, 36, 37, 40, 42, 43, and 46 are obvious over Ritter in view of the RFID Handbook and Vega.

  • Prior Art Relied Upon: Ritter (WO 98/58510), the RFID Handbook (RH-E/RH-G), and Vega (Patent 6,282,407 and Patent 6,275,681).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1 to specifically address claims requiring a signal to be detected "as if" it were generated by a traditional load modulation switch, even without such a switch. Petitioner asserted that Ritter disclosed powering its mobile device from its main battery when in transponder mode to achieve greater transmission distances. A POSITA would understand this to mean using "active transmission." The Vega patents explicitly taught a modulator circuit for achieving this exact function—using "active transmission" to simulate switch-based load modulation by generating and transmitting a modulated carrier signal under local power. This technique, taught by Vega, was specifically intended to increase the read range, directly aligning with the objective described in Ritter. Therefore, Vega supplied the express teaching for the "as if" limitation.
    • Motivation to Combine: A POSITA, having combined Ritter and the RFID Handbook, would be motivated to incorporate Vega’s teachings to implement Ritter's suggestion of using battery power for greater transmission range. Vega provided a known, advantageous solution ("active transmission") to the problem of extending communication distance in RFID-style systems. The shared goal of achieving a longer read range provided a clear and compelling reason to combine Ritter’s battery-powered mode with Vega’s specific circuit implementation.
    • Expectation of Success: Vega taught that its active transmission modulator could be implemented in inductively coupled systems. Therefore, a POSITA would have reasonably expected that incorporating Vega's modulator design into Ritter's inductively coupled mobile device would successfully achieve active transmission and its predictable benefit of an extended communication range.

4. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel claims 13-15, 18-20, 23-25, 36, 37, 40, 42, 43, and 46 of the ’770 patent as unpatentable under 35 U.S.C. §103.