PTAB

IPR2016-01336

TrickleStar LLC v. EmberTec Pty Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: POWER MONITORING SYSTEM
  • Brief Description: The ’099 patent discloses a power management system that plugs into a main power outlet and provides multiple controlled outlets for external electrical devices. The system reduces "vampire" power consumption by monitoring for wireless remote control signals and terminating power to a device when no user activity is detected for a period of time or when the device enters a standby state.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-4, 7, 9, and 10 under §102 over EP'379

  • Prior Art Relied Upon: EP'379 (European Patent Application # EP2051379A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that EP'379 discloses every element of the challenged independent claims. EP'379 describes a power-saving controller for home automation that connects to a main power supply (the claimed "input") and provides multiple sockets for external devices (the claimed "outputs"). The controller includes a microprocessor (the claimed "processor") and a signal receiving unit, such as an infrared receiver (the claimed "sensor"), to monitor signals from a remote control. Critically, Petitioner argued EP'379 teaches that its processor terminates power to a connected device based on the absence of a detected remote control signal for a predetermined time period, directly mapping to the core limitation of claims 1, 9, and 10. For dependent claims, EP'379 was argued to disclose monitoring for both RF and IR signals (claims 2-3), terminating power after a timeout period (claim 4), and providing a plurality of outputs (claim 7).

Ground 2: Obviousness of Claims 5, 6, 8, 11, and 12-16 under §103 over EP'379 in view of EP'752

  • Prior Art Relied Upon: EP'379 (European Patent Application # EP2051379A1) and EP'752 (European Patent Application # EP1223752A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that EP'379 provides the base system of a multi-outlet, remote-controlled power-saving device, as established in Ground 1. EP'752 was introduced to supply the features missing from EP'379. Specifically, EP'752 teaches an energy-saving device that includes a power sensor (e.g., a Hall Effect sensor) to monitor the power consumption of an appliance and determine its operational state (ON vs. standby). EP'752 also explicitly discloses providing a visual or audible alert (e.g., an LED or buzzer) to warn a user before power is disconnected. Petitioner argued these teachings render obvious the limitations in the remaining claims, such as adding an "alert device" (claims 5-6), a "power sensor" to determine operational state (claim 8), and a "warning device" (claim 11). For independent claim 12, EP'379 provided the base system with communication apparatus (USB bus), while EP'752 provided the claimed "power sensor" and the logic for controlling power in response to a sensed power consumption state.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine EP'379 and EP'752 because both address the identical problem of reducing power wastage from electronic devices in standby mode. A POSITA would have been motivated to integrate the specific power-sensing capabilities and user-friendly alert features from EP'752 into the more comprehensive, multi-device home automation system of EP'379. This combination would create a more robust and effective power-saving product by allowing it to react to actual power states rather than just remote control inactivity, and by preventing abrupt, unexpected power shutdowns.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because the combination involved integrating well-understood components (power sensors, LEDs, buzzers) and applying conventional software logic. The resulting system would predictably perform the functions described in each reference.

4. Key Claim Construction Positions

  • "electrical inlet / electrical input / input / electrical plug": Petitioner proposed these interchangeable terms mean "a power or electrical line for connecting a power supply to the energy saving device." This construction was used to argue that the main power connection shown in the prior art figures met the limitation.
  • "sensor / device sensor": Petitioner proposed these terms mean "any signal detection device that detects any kind of wireless signal from a remote controller." This broad construction allowed Petitioner to map the infrared receiver in EP'379 to this limitation.
  • "alert device": As the term does not appear in the ’099 patent's specification, Petitioner proposed it should be construed based on disclosed "monitoring facilities" like beepers and LEDs. The proposed construction was "any device which can send out a visual or audible signal to a user," which enabled mapping to the signaling devices in EP'752.

5. Relief Requested

  • Petitioner requested institution of an inter partes review for claims 1-16 of the '099 patent and cancellation of all challenged claims as unpatentable.