PTAB

IPR2017-00067

Superior Communications Inc v. Voltstar Technologies Inc

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1. Case Identification

2. Patent Overview

  • Title: ENERGY-SAVING POWER ADAPTER/CHARGER
  • Brief Description: The ’833 patent discloses a power adapter for portable electronic devices that includes a switch assembly. The switch cuts off input power to the adapter's internal circuitry when not charging a device, thereby eliminating standby or "vampire" power consumption.

3. Grounds for Unpatentability

Ground 1: Anticipation over Sakamoto - Claims 1-3, 6-10, and 56-58 are anticipated by Sakamoto.

  • Prior Art Relied Upon: Sakamoto (Japanese Disclosure No. JP2003-284342).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sakamoto, which discloses an AC adapter for devices like computers or cell phones, teaches every limitation of the challenged claims. Independent claim 1’s key elements were mapped as follows: a first portion for receiving AC input (Sakamoto’s AC plug), a second portion for delivering DC output (Sakamoto’s DC plug), a removable connector, and a switch assembly to place the device in an ‘on’ or ‘off’ state. Sakamoto’s switch assembly, particularly in its first embodiment (Switch Assembly 1A), is actuated by the physical insertion or removal of the DC plug into an electronic device, which directly corresponds to the ‘on’ and ‘off’ states that control power draw from the AC source. Dependent claims relating to toggle throws, manual operation, and cable configurations were argued to be disclosed in Sakamoto’s alternative embodiments (e.g., Switch Assembly 1B).

Ground 2: Obviousness over Noguchi, Suzuki, and Huang - Claims 11, 12, 17, 18, 20, and 21 are obvious over Noguchi in view of Suzuki and Huang.

  • Prior Art Relied Upon: Noguchi (Japanese Disclosure No. JP2002-199612), Suzuki (Patent 6,489,725), and Huang (Application # 2002/0115480).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Noguchi discloses a base charger with circuitry for converting AC to DC power and determining an ‘off’ state, for example, when a cell phone is fully charged or removed from the charger. Noguchi’s charger, however, lacks a physical connector for the device. Huang was introduced to supply this missing element, as it teaches the common use of a "cellular telephone connector" to removably connect a phone to a charging base. Suzuki was introduced to teach modifying Noguchi’s electronic switch to a latching relay, which Petitioner argued was a functionally equivalent and well-known alternative for switching power.
    • Motivation to Combine: A POSITA would combine Noguchi with Huang to improve the stability of the device in the charger cradle and to make the charger compatible with phones that use female power ports, which was a known design choice. A POSITA would incorporate Suzuki’s latching relay into Noguchi’s circuit to reduce power consumption needed to maintain the switch in a given state and to protect the solid-state switch from power surges, a known vulnerability.
    • Expectation of Success: The combination involved applying conventional components (connectors, relays) to their known functions in a predictable manner, ensuring a high expectation of success.

Ground 3: Obviousness over Eishi and Luu - Claims 11, 12, 17, 18, 20, and 21 are obvious over Eishi in view of Luu.

  • Prior Art Relied Upon: Eishi (Japanese Disclosure No. 2002-125315) and Luu (Patent 7,140,922).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Eishi discloses a "power cutoff device" with most elements of claim 11, including circuitry for determining an ‘off’ state by sensing current draw and using a comparator to open a relay contact when power falls below a threshold. However, Eishi was primarily described for AC output. Luu was introduced to teach modifying Eishi to supply DC power, as Luu discloses power strips with integrated AC/DC adapters and DC receptacles for powering laptops.
    • Motivation to Combine: A POSITA would combine Eishi’s power-saving control circuitry with Luu’s DC power delivery system to satisfy the known need for energy-efficient chargers for DC-powered devices like laptops. This modification would simply apply Eishi’s AC power-sensing concept to a DC circuit, which was a straightforward adaptation.
    • Expectation of Success: Modifying Eishi’s current sensor to detect DC current draw from Luu’s DC cable was presented as a predictable design choice for a POSITA seeking to create a power-saving DC adapter.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claim 4 is obvious over Sakamoto and Odaohhara (Patent 6,986,067) to replace a pin with a more durable sheath; claim 16 is obvious over the Noguchi combination and Byun (Korean Patent Publication No. 10-2006-0008699) to add a timer delay; and claim 22 is obvious over Noguchi, Suzuki, Sakamoto, and Odaohhara to create a charger with a corded, sheath-based switch for laptops.

4. Key Claim Construction Positions

  • "output signal" (claims 11, 12, 18): Petitioner proposed that under the broadest reasonable interpretation, this term should include any voltage or current that carries information, including the simple transmission of electricity from one point to another to control a component. This construction was based on the ’833 patent’s description where pressing a button delivers power to a relay coil, with the delivery of power itself being the "signal." This broad construction was important for arguing that the prior art’s simple electrical connections met this limitation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate because the petition presented new prior art and arguments not considered during a previous inter partes reexamination of the ’833 patent. Specifically, the primary references (Sakamoto, Noguchi, Eishi) were asserted to be entirely new. It was argued that while some secondary references were used in the prior reexamination, they were used in different combinations and for different purposes in this petition, thus raising new unpatentability questions.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6-12, 16-18, 20-22, and 56-58 of the ’833 patent as unpatentable.