PTAB

IPR2017-01331

Power Integrations Inc v. Semiconductor Components Industries LLC

Log In
Key Events
Petition
petition Intelligence

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 for powering LEDs. The technology describes an LED driver circuit that utilizes a programmable input signal to control the output current and/or brightness of the LEDs, with stated objectives of improving the power factor (PF) and enabling dimming control.

3. Grounds for Unpatentability

The petition asserts a single ground for unpatentability, arguing that all challenged claims are anticipated by a single prior art reference that was not considered during the original prosecution of the ’764 patent.

Ground 1: Anticipation of Claims 1, 6, 10, 13, 16, and 22 under 35 U.S.C. §102(e) over Saint-Pierre

  • Prior Art Relied Upon: Saint-Pierre (Patent 8,098,506).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Saint-Pierre discloses every element of the challenged claims. The core of the argument rested on the assertion that Saint-Pierre’s primary-side controlled LED driver circuit, designed to achieve high power factor correction, functions identically to the circuit described in the ’764 patent.
      • Independent Claim 1: Petitioner contended that Saint-Pierre's controller (e.g., controller 585), magnetic device (transformer T1), and LED load meet the structural requirements of the claim. Crucially, Petitioner asserted that the "input voltage sense signal URECT" disclosed in Saint-Pierre is a "programmable signal" under the proper claim construction. This signal is a variable voltage derived from the AC input that is coupled to regulate a "current-control signal" (the "scaled current signal 146") within an arithmetic operator circuit. Petitioner argued that Saint-Pierre further discloses modulating the switching signal in response to this current-control signal to regulate the output current, thereby anticipating every limitation of claim 1.
      • Independent Claim 6: This claim is nearly identical to claim 1 but recites "control[ling] a reference signal" instead of "regulat[ing] a current-control signal." Petitioner argued this is a distinction without a difference in the context of Saint-Pierre, which explicitly teaches using the "programmable signal" (URECT) to generate a reference signal (the "input charge control signal UQ") that is then used in a comparator to control switching.
      • Independent Claim 10: This claim recites modulating a "current input signal" rather than a "current-control signal." Petitioner mapped this to Saint-Pierre's disclosure where the programmable input (URECT) is used to modulate the switching current, which in turn directly modulates the "current input signal" (UIN), a signal representative of the primary side switching current.
      • Independent Claim 13: This claim adds the limitation that the programmable signal is "generated in response to an input of the LED drive circuit." Petitioner argued this is explicitly taught by Saint-Pierre, where the URECT signal is derived directly from the rectified input voltage of the power supply.
      • Independent Claim 16: This claim recites an input circuit that receives a programmable signal to generate a "programmable current" for controlling a current input signal. Petitioner mapped this to Saint-Pierre's circuit where the controller receives the voltage sense signal (URECT) as a current (IRECT) that is representative of the input voltage, and this programmable current is used to control the switching current and thus the current input signal.
      • Independent Claim 22: This claim specifies a "primary-side controller." Petitioner argued Saint-Pierre clearly discloses this feature, as its controller derives feedback from a bias winding on the primary side of the transformer to regulate the output, avoiding the need for an opto-coupler.

4. Key Claim Construction Positions

Petitioner dedicated a section to construing a single term that it deemed critical to its anticipation argument for all challenged claims.

  • "programmable signal" (recited in all independent claims):
    • Proposed Construction: Petitioner argued for the broadest reasonable construction, defining the term as "a selectable or potentially variable voltage or current signal."
    • Argument for Construction: The core of Petitioner's argument was that the '764 patent's specification does not limit the term to a signal requiring digital programming or direct human input. Instead, the patent's only described embodiment shows the programmable signal (VCNT) being generated in response to the analog AC input voltage (VAC). Petitioner also invoked the doctrine of claim differentiation, noting that dependent claim 3 narrows the "programmable signal" to one "generated in response to an AC input," implying the term in the independent claim must be broader. This broad construction was essential for Petitioner's argument that Saint-Pierre’s analog "input voltage sense signal" meets the limitation.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 1, 6, 10, 13, 16, and 22 of Patent 9,049,764 as unpatentable.