PTAB

IPR2016-01066

Polygroup Macau Ltd v. Variable Lighting LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Variable-Effect Lighting System
  • Brief Description: The ’140 patent discloses a variable-effect lighting system for decorative and ornamental displays. The system uses a programmable lamp controller to independently adjust the conduction angle of multiple illuminating elements (e.g., red and green LEDs within a bicolored lamp), thereby producing a variety of colors and lighting patterns from a single lamp assembly.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, and 5 are obvious over Kazar in view of Gomoluch.

  • Prior Art Relied Upon: Kazar (Patent 5,008,595) and Gomoluch (International Publication No. WO 91/19379).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kazar, which is directed to LED light displays, taught every element of claim 1 except for an explicitly "programmable" controller that stores predetermined patterns in memory. Kazar disclosed a variable-effect lighting system with a plurality of multi-colored, bicolored LED lamps connected in parallel to a DC source. Kazar’s controller used Pulse Width Modulation (PWM) to vary the on-time of the red and green LEDs, which Petitioner contended was equivalent to setting a "conduction angle" to produce different colors based on predetermined patterns (e.g., 50% duty cycle for yellow). Gomoluch was cited to teach the missing element: a programmable controller for an LED lighting system comprising a microprocessor connected to a pattern and program store (memory) to call up predefined bit patterns.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine these references because it would have been a simple and obvious improvement to enhance Kazar’s LED display system with the known technique of a programmable, memory-based controller as taught by Gomoluch. This would predictably improve Kazar's functionality by allowing for more complex, stored color patterns.
    • Expectation of Success: A POSA would have had a high expectation of success, as combining a standard programmable controller with an existing LED driver circuit was a well-understood and common practice in the art.

Ground 2: Claims 6-9 are obvious over Kazar in view of Sato and further in view of Gomoluch.

  • Prior Art Relied Upon: Kazar (Patent 5,008,595), Sato (Patent 5,757,111), and Gomoluch (International Publication No. WO 91/19379).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims directed to a "night light." Petitioner asserted that Kazar taught the core variable-effect LED lighting circuit, but was silent on its use as a night light. Sato was introduced to supply this limitation, as it explicitly disclosed a "night light" that included an ambient light sensor. The combination of Kazar and Sato was argued to teach most elements, with Gomoluch again added to provide the "programmable" controller with stored patterns, a feature not expressly taught by Kazar or Sato. Claim 9's ambient light sensor was taught directly by Sato's photoelectric transducer.
    • Motivation to Combine: A POSA would combine Kazar with Sato to implement Kazar’s more advanced and efficient multi-color LED technology into the well-known application of a night light, replacing Sato's incandescent bulb to gain benefits like lower power consumption and longer life. A POSA would further add Gomoluch's programmability to this night light to provide enhanced, user-selectable lighting patterns, which was a known method to improve such devices.
    • Expectation of Success: The combination involved applying a known technology (LEDs) to a known application (night lights) and improving it with a standard component (programmable controller), leading to predictable results.

Ground 3: Claims 1, 2, 4, and 5 are obvious over Smith in view of Gomoluch.

  • Prior Art Relied Upon: Smith (Patent 4,675,575) and Gomoluch (International Publication No. WO 91/19379).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented a parallel argument to Ground 1, substituting Smith for Kazar as the primary reference. Petitioner argued Smith taught a light bulb assembly with bi-color light sources, a controller for sequencing colors, and multi-color lamps in parallel with a DC source. Smith’s "variable duty cycle control circuit" was argued to teach setting a conduction angle according to a predetermined pattern. Like Kazar, Smith did not explicitly teach storing these patterns in a programmable controller's memory. Gomoluch was again relied upon to supply this missing element. For claim 5, Smith was alleged to teach an H-bridge circuit for driving the LEDs.
    • Motivation to Combine: The motivation was identical to Ground 1: a POSA would have found it obvious to enhance Smith’s lighting system with Gomoluch's programmable controller to improve the device in a predictable manner by adding the capability to store and select from multiple predefined lighting sequences.
    • Expectation of Success: As with the Kazar combination, integrating Gomoluch’s programmable controller with Smith’s lighting circuit was a straightforward application of known techniques with a high likelihood of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Kazar/Gomoluch with Minato (for a temperature sensor) and Lys (for a jewelry piece application), as well as parallel grounds substituting Smith for Kazar in those combinations.

4. Key Claim Construction Positions

  • "variable-effect lighting system": Petitioner proposed this term means "a lighting system where one of the lighting effects—e.g., the color of the light—can be changed." This construction was argued to be consistent with the patent’s title and disclosure, which focuses on controlling the color of light.
  • "conduction angle of each said illuminating element": Petitioner proposed this term means "a portion of a whole period of a periodic waveform at which the illuminating element conducts current—i.e., when the lighting element turns on." This construction equates the claimed "conduction angle" with the concept of a duty cycle, a common technique in the prior art (e.g., Kazar's PWM) for controlling LED brightness and color mixing.
  • "a pair of commonly-coupled light-emitting diodes": Petitioner proposed this term means "a pair of light-emitting diodes with at least one terminal coupled together." This broad construction was supported by figures in the ’140 patent and was used to map onto prior art LED configurations.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-13 of the ’140 patent as unpatentable under 35 U.S.C. §103.