PTAB

IPR2018-00425

Samsung Electronics America, Inc. v. Fundamental Innovation Systems International LLC

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1. Case Identification

2. Patent Overview

  • Title: Charging and Power Supply for Mobile Devices
  • Brief Description: The ’655 patent relates to power management circuits for mobile devices that receive power from a limited external source, such as a USB port. The invention purports to solve the problem of power starvation by using battery isolation circuitry, including a field-effect transistor, to variably restrict current to the rechargeable battery when the electronic system's power demand is high, thereby prioritizing the system's operation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Veselic and Vyssotski - Claim 1 is obvious over Veselic in view of Vyssotski.

  • Prior Art Relied Upon: Veselic (Application # 2004/0164708) and Vyssotski (Application # 2004/0019815).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Veselic taught the core power allocation method of claim 1. Veselic disclosed a circuit for use with limited power sources (like USB) that monitors the voltage at a node supplying both a portable device and a battery. When this voltage drops below a minimum value, the circuit restricts current to the battery, thereby allocating more power to the portable device. Petitioner asserted this met most limitations of claim 1 but used a fixed minimum voltage threshold. Vyssotski was argued to supply the missing elements by teaching a system that generates a dynamic voltage reference corresponding to a device's specific operating state (e.g., sleep, wake, normal). Petitioner contended that using Vyssotski’s decoder to provide a variable reference voltage to Veselic’s sensing circuit rendered all limitations of claim 1 obvious.
    • Motivation to Combine: Petitioner argued that Veselic itself contemplated that a portable device has multiple operating states (e.g., "sleep" and "wake") with different power requirements. A POSITA would recognize that Veselic’s fixed voltage threshold, set for the highest power state, would be inefficient and would unnecessarily throttle battery charging in lower power states. A POSITA would combine Veselic with Vyssotski’s teaching on dynamically adjusting voltage references based on operating states to create a more efficient and responsive power management system.
    • Expectation of Success: Petitioner asserted that integrating Vyssotski’s decoder into Veselic’s system was a simple and predictable combination. A POSITA would have readily understood that the voltage output reference from Vyssotski's decoder could be used as the reference voltage input for the voltage sensing circuit in Veselic, constituting a combination of familiar elements to yield predictable results.

Ground 2: Obviousness over Veselic, Vyssotski, and Kranzen - Claims 2-11 are obvious over Veselic and Vyssotski in view of Kranzen.

  • Prior Art Relied Upon: Veselic (Application # 2004/0164708), Vyssotski (Application # 2004/0019815), and Kranzen (Patent 7,570,020).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this combination rendered the dependent claims obvious. Veselic taught a generic "battery charge controller" but did not specify its type. Kranzen taught the specific features recited in the dependent claims by disclosing an efficient switch-mode battery charger and voltage regulator system. Specifically, Kranzen taught using an "inductive-based buck regulation" circuit, which inherently provides output power with a higher current and lower voltage than the input power, meeting the limitations of claim 2. Kranzen further disclosed this charger as an integrated circuit (IC) that cooperates with an external inductor, as recited in claim 3. For claims requiring power conversion from the battery (e.g., claims 4, 6, 9), Kranzen explicitly taught a switch-mode DC-DC converter to efficiently down-convert battery voltage to power the system.
    • Motivation to Combine: Petitioner contended that a POSITA, having combined Veselic and Vyssotski, would seek to implement Veselic's generic "battery charge controller" with a known, efficient, and space-saving circuit. Kranzen provided just such a solution with its switch-mode charger IC. A POSITA would combine Kranzen’s specific, superior component into Veselic's power management framework as a predictable design choice to achieve the obvious benefits of higher efficiency and component integration, which are critical in portable devices. This was presented as a classic substitution of a known element for a generic one to obtain a predictable improvement.
    • Expectation of Success: Petitioner argued that replacing Veselic's generic controller with Kranzen's well-defined switch-mode charger IC would be a straightforward task for a POSITA. The function and interfaces of such components were well understood in the art, leading to a high expectation of success in creating the combined system.

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-11 of the ’655 patent as unpatentable under 35 U.S.C. §103.