PTAB

IPR2016-01546

Generation Brands LLC v. Lighting Science Group Corp

Key Events

Petition

petition

Title: Low-Profile LED Luminaire with Heat Dissipation System
Brief Description: The ’844 patent discloses a low-profile LED luminaire designed for efficient heat dissipation. The invention uses a heat spreader to conduct heat from an LED light source to a substantially ring-shaped heat sink disposed at the periphery, which also serves as the fixture’s outer trim, and includes a power conditioner sized to fit within a standard electrical junction box or recessed can light fixture.

Prior Art Relied Upon: Chou (Patent 7,670,021) and Wegner (Patent 7,993,034).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Chou’s low-profile LED fixture disclosed the core claim elements. Specifically, Chou’s single-piece metal "trim 12" was alleged to function as both the claimed "heat spreader" (the inner portion where LEDs are mounted) and the "heat sink" (the outer, ring-shaped flange that dissipates heat into the room). Chou further disclosed an AC/DC power conditioner sized to fit within a recessed can light fixture.
- Motivation to Combine: While Chou is designed for recessed cans, Petitioner asserted a POSITA would combine its teachings with Wegner to serve the large and well-known new construction market, which predominantly uses electrical junction boxes. Wegner explicitly taught adapting an LED luminaire for direct wiring, which would be necessary to connect Chou's device in a junction box.
- Expectation of Success: The combination required only selecting an appropriately scaled, commercially available power conditioner to fit within the shallower dimensions of a standard junction box. Petitioner argued this was a predictable modification with a high expectation of success.

Prior Art Relied Upon: Soderman (Patent 7,980,736), Chou (Patent 7,670,021), and Silescent (a commercial product installation guide).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended Soderman disclosed a low-profile fixture with a "mounting assembly" (18) acting as a heat spreader and a surrounding ring-shaped "cover structure" (20) acting as a heat sink. However, Soderman did not explicitly teach an AC/DC power conditioner. Chou was introduced to supply this element, teaching a compact power conditioner placed on the back of the fixture. Silescent, the commercial embodiment of Soderman, was used to provide specific dimensions satisfying dependent claims (e.g., H/D ratio < 0.25) and to confirm that the final product was designed to be powered by a conditioner located within a standard UL-approved junction box.
- Motivation to Combine: A POSITA would be motivated to add Chou's power conditioner to Soderman's fixture to make it operable in common residential and commercial environments requiring AC-to-DC conversion. The Silescent literature demonstrated that this exact combination was not only logical but commercially implemented, providing a strong motivation.
- Expectation of Success: Implementing Soderman with a power conditioner from Chou and the dimensions from Silescent would predictably result in the claimed invention, as it merely involved assembling known components for their intended purposes.

Prior Art Relied Upon: Zhang (Patent 7,722,227).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Zhang alone disclosed a luminaire with all the key features. Zhang's "trim cup" (112), where the LEDs are mounted, was identified as the heat spreader. The integrated "trim unit," comprising a baffle and trim ring (52, 54), was identified as the surrounding, ring-shaped heat sink that dissipates heat. Zhang also explicitly disclosed an AC/DC driver (42) that fits entirely within a recessed can.
- Motivation to Combine (for modification): To meet the "junction box" limitation, Petitioner argued it would have been obvious for a POSITA to select a different, commercially available driver appropriately sized to fit within a standard electrical junction box. The motivation was to adapt Zhang's design to serve the broader new construction market.
- Expectation of Success: Scaling or selecting a suitable driver was a simple design choice based on known components and market demands, yielding a predictable result.
Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Chou/Wegner/Zhang (Claim 10), Soderman/Wegner/Chou/Silescent (Claim 17), Zhang/Wegner (Claim 17), and Zhang/Soderman (Claim 20), which relied on similar principles of adding features like an inner optic, an Edison adapter kit, or mounting holes from secondary references to address specific dependent claim limitations.

"heat spreader" and "heat sink": Petitioner argued that under the broadest reasonable interpretation, the "heat spreader" is the component that moves heat from the LED source to the "heat sink," which is the component that dissipates the heat into the ambient air. This construction allows a single, integrally formed prior art component to satisfy both limitations if different portions perform these distinct functions.
"ring-shaped": Petitioner proposed a construction of "generally round with a hole in the middle," which does not require perfect circularity. This broad interpretation was asserted to encompass the structures disclosed in the prior art, such as flanges and trims that are not perfectly circular.
"nominally sized ... electrical junction box": Petitioner contended this term includes a wide range of commercially available and UL-approved sizes, such as 4-inch, 5-inch, and 6-inch boxes. This interpretation is central to the argument that modifying prior art fixtures with available power conditioners to fit such boxes would have been obvious.

Functional Interpretation of Integrated Structures: A core technical contention advanced by Petitioner was that a single, unitary metal component in the prior art (e.g., a trim piece with a central mounting area and an outer flange) should be analyzed based on the distinct thermal functions of its different regions. Petitioner argued that the inner portion functions as the claimed "heat spreader" by conducting heat, while the outer, air-exposed portion functions as the claimed "heat sink" by dissipating that heat, thereby satisfying both limitations of claim 1.

Petitioner requests the institution of an inter partes review and cancellation of claims 1-3, 5, 7, 9, 10, 12, 14, 16, 17, and 20-24 of Patent 8,967,844 as unpatentable.