PTAB

IPR2017-01329

Power Integrations Inc v. Semiconductor Components Industries LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: LED DRIVE CIRCUIT WITH A PROGRAMMABLE INPUT FOR LED LIGHTING
  • Brief Description: The ’764 patent relates to switch-mode power supplies used to power LEDs. The technology describes an LED power supply with a programmable input used to control the brightness of the LED and/or control the current that flows through the LED load.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 6, 10, 13, and 14 under 35 U.S.C. §102

  • Prior Art Relied Upon: Yang (Patent 7,245,089).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yang (’089 patent), which shares a common inventor with the challenged patent, discloses every element of the challenged independent claims. The ’089 patent teaches an LED driver with a controller that generates a switching signal to control a switch coupled to a magnetic device (an inductor), thereby generating an output current to drive a plurality of LEDs. Petitioner asserted that the ’089 patent also discloses two separate programmable inputs—a control voltage (VCNT) and a reflected signal (VD)—that are used to regulate or control a current-control signal or a reference signal within the controller. This regulation modulates the final switching signal to control the output current supplied to the LEDs, directly mapping to the limitations of claims 1, 6, 10, and 13. Claim 14, which depends on claim 13, was argued to be anticipated because the programmable inputs in Yang '089 provide feed-forward control of the output current.

Ground 2: Obviousness of Claims 4, 11, 15-18, and 21-23 over Yang '089 and Yang '824

  • Prior Art Relied Upon: Yang (Patent 7,245,089) and Yang (Patent 6,977,824).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that this combination renders obvious claims that add a "primary-side controller" limitation. Yang '089 teaches the core programmable LED driver circuit, as established in Ground 1. Yang '824, which is cited as prior art within the ’764 patent itself, discloses a primary-side controlled regulator with a controller architecture that is essentially identical to that of the ’764 patent, but without the programmable input feature. The combination of Yang '089’s programmable control with Yang '824’s primary-side controller was argued to teach all elements of the challenged claims.
    • Motivation to Combine: A POSITA would combine the teachings because both patents are from the same inventor, operate in the same field of switching power supplies, and address similar control problems. A POSITA would be motivated to apply the known technique of a programmable input from Yang '089 to the primary-side controller of Yang '824 to achieve the known benefits of programmable current control while retaining the safety and performance advantages (e.g., galvanic isolation) of a primary-side architecture.
    • Expectation of Success: Success would be predictable, as this combination involves applying a known improvement (programmable input) to a similar, well-understood circuit (primary-side controller) to achieve a predictable result.

Ground 3: Obviousness of Claims 5, 9, and 12 over Yang '089, Yang '824, and the Yang '0420 Application

  • Prior Art Relied Upon: Yang (Patent 7,245,089), Yang (Patent 6,977,824), and Yang (Application # 2008/0170420).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination in Ground 2 to address claims requiring a sample-and-hold circuit that stops sampling when an input voltage falls below a low-voltage threshold. The combination of Yang '089 and Yang '824 provides the foundational programmable, primary-side LED driver. The Yang ’0420 application, also cited as prior art in the ’764 patent, explicitly teaches an under-voltage protection circuit for a primary-side controller. This circuit detects when the input voltage is below a threshold and generates a control signal to stop the switching operation of the power supply.
    • Motivation to Combine: A POSITA would be motivated to add the under-voltage protection circuit from the ’0420 application to the combined Yang '089/’824 controller. Adding such protection is a routine design choice to improve the reliability and safety of a power supply. Since Yang '824 already discloses a sample-and-hold circuit whose operation is tied to the switching signal, stopping the switching operation (as taught by the ’0420 application) would inherently stop the sampling, thus meeting the claim limitation.
    • Expectation of Success: The integration of a standard protection circuit into a power converter controller would be straightforward for a POSITA and would yield the predictable result of enhanced safety.

4. Key Claim Construction Positions

  • "Programmable Signal" (claims 1, 6, 10, 13, 16, and 22):
    • Petitioner proposed the construction "a selectable or potentially variable voltage or current signal."
    • Petitioner argued this construction is consistent with the specification's only embodiment, where the signal is generated in response to an AC input, and is necessary to preserve the validity of dependent claims that further narrow the source of the signal. Petitioner contended that under the broadest reasonable interpretation, the term does not imply any specific content or require human input.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4-6, 9-18, and 21-23 of Patent 9,049,764 as unpatentable.