PTAB

IPR2018-00508

LG Electronics, Inc. v. Fundamental Innovation Systems International LLC

Log In

1. Case Identification

2. Patent Overview

  • Title: Multifunctional Charger System and Method
  • Brief Description: The ’766 patent discloses a system for charging a mobile device via a USB adapter. The system enables the mobile device to draw current in excess of standard USB Specification limits by having the adapter transmit a special "identification signal"—an abnormal USB data condition, such as applying a voltage greater than 2V to both the D+ and D- data lines—which informs the device that the higher power draw is permissible without requiring a standard USB enumeration process.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dougherty, DeJaco, and Shiga - Claims 1-24 are obvious over Dougherty in view of DeJaco and Shiga.

  • Prior Art Relied Upon: Dougherty (Patent 7,360,004), DeJaco (Patent 6,745,024), and Shiga (Patent 6,625,738).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Dougherty taught the core concept of a mobile device (a laptop) with a charging subsystem that draws power far exceeding USB limits (up to 2.5 amps at 18 volts) from a docking station over a USB interface. Dougherty achieved this after a complex handshaking protocol. DeJaco was introduced to render obvious the inclusion of wireless communication capabilities (e.g., a wireless modem) in Dougherty's laptop, thereby meeting the full scope of a "mobile device" as described in the ’766 patent. Shiga taught using a simple, abnormal USB data condition—the "SE1 state" where both D+ and D- lines are held high (e.g., at 3 volts)—for non-standard signaling. Petitioner argued it would have been obvious to replace Dougherty's complex and time-consuming handshaking protocol with Shiga's simple and easily distinguishable SE1 state to signal the availability of high-power charging. This combination allegedly taught a mobile device enabled to draw unrestricted current in response to detecting an abnormal data condition on its USB communication path, without USB enumeration.
    • Motivation to Combine: A POSITA would combine Dougherty and DeJaco to add the known benefits of wireless communication to a portable computer. A POSITA would be motivated to replace Dougherty's handshaking protocol with Shiga's SE1 signaling to achieve Dougherty's own stated goal of reducing the time and complexity of coupling the laptop to the docking station. Shiga's method provided a logical and less complex alternative for identification.
    • Expectation of Success: Combining these known elements for their established functions—a laptop with wireless, a high-power USB charger, and a non-standard USB signal—would have produced predictable and operable results. Implementing Shiga's simple signaling in Dougherty's system was argued to be a straightforward modification for a POSITA.

Ground 2: Obviousness over Theobald, USB 2.0, and Shiga - Claims 17-23 are obvious over Theobald in view of the USB 2.0 Specification and Shiga.

  • Prior Art Relied Upon: Theobald (Patent 5,925,942), the Universal Serial Bus Specification, Revision 2.0 (USB 2.0), and Shiga (Patent 6,625,738).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Theobald disclosed a method of charging a mobile device (a cell phone) using a "fast rate charger" accessory that supplied current (850 mA) exceeding the later USB 2.0 standard's high-power limit (500 mA). Theobald's charger used a microcontroller to send an identification signal to the phone over a proprietary connector. The USB 2.0 specification taught a standard, ubiquitous four-conductor connector (VBUS, GND, D+, D-) for power and data. Petitioner contended it would be obvious to implement Theobald's proprietary connector as a standard USB 2.0 connector. Shiga again supplied the teaching of using the SE1 state (D+/D- high) as an identification signal over the D+/D- lines. The combination allegedly taught a method where, upon detection of the SE1 identification signal via the USB path, the device would draw current (850 mA) in excess of the USB Specification limit. For the limitation of drawing current in accordance with the USB Specification if the signal is not detected, Petitioner argued a POSITA would find it obvious for the device to draw standard power from a USB host/hub when the fast-charger accessory was disconnected.
    • Motivation to Combine: A POSITA would be motivated to replace Theobald's proprietary connector with a standard USB 2.0 connector to achieve interoperability, reduce costs, and access a wider ecosystem of accessories—goals consistent with Theobald's focus on a "low cost apparatus." Further, combining with Shiga would allow the use of existing USB data lines (D+/D-) for identification signaling, eliminating the need for separate pins and reducing hardware cost and complexity, which was a clear benefit.
    • Expectation of Success: Modifying a charger to use a standard USB interface and leveraging the data lines for simple signaling were well-understood techniques that would yield the predictable result of a functional, interoperable, and lower-cost charging system.

4. Key Claim Construction Positions

  • "USB enumeration": Petitioner contended this term should be construed to mean the specific, host-initiated bus-enumeration procedure defined in the USB 2.0 Specification. This construction is central to arguments for claims requiring charging to occur "without USB enumeration," as it limits the term to a formal, multi-step process that is bypassed by the invention's abnormal signaling.
  • "drawing current in accordance with said USB Specification": Petitioner proposed this phrase covers two distinct scenarios taught by the USB 2.0 Specification: (1) a device drawing power over the USB cable within the defined current limits (e.g., 500 mA), and (2) a self-powered device drawing current from its own power supply via a power management system that is independent of the USB bus. This construction is critical to Petitioner's argument for claim 17, which recites this step as an alternative action taken when the special identification signal is not detected.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate because the grounds presented were not considered by the examiner during prosecution. The petition relied on new combinations of prior art (Dougherty/DeJaco/Shiga and Theobald/USB 2.0/Shiga) and was supported by new declaration testimony from an expert, Dr. Wood, presenting arguments that were not previously before the Office.

6. Relief Requested

  • Petitioner requested the Board institute an inter partes review and cancel claims 1-24 of the ’766 patent as unpatentable.