PTAB

IPR2018-00921

Feit Electric Co Inc v. Philips Lighting Holding BV

Key Events

Petition

Title: System for Supplying Power for an LED Array
Brief Description: The ’890 patent discloses driver circuits for powering LED arrays, particularly for automotive applications. The technology uses pulse width modulation (PWM) and current feedback to maintain a nominal operating current, aiming to improve regulation, efficiency, and LED lifespan.

Prior Art Relied Upon: Biebl (Patent 6,400,101).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Biebl’s LED drive circuit discloses all limitations of claim 1. Biebl’s internal oscillator generates a sawtooth waveform which, when input to a comparator with a regulation voltage, creates an oscillating signal with a first and second state. A transistor in Biebl acts as a power supply responsive to this signal, providing power to an LED array only when the signal is in its first state. For dependent claims 22 and 30, Petitioner asserted that Biebl’s fault detection circuit, which uses a comparator to detect a voltage drop and output a status signal, meets the limitation of indicating when the LED array is inoperable.
- Motivation to Combine (for §103 grounds): Not applicable for a single-reference ground.
- Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

Prior Art Relied Upon: Biebl (Patent 6,400,101), TI Book (Texas Instruments Power Supply Control Products Data Book, 1999), and Hamp (Application # 2001/0033503).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that while Biebl teaches the functionality of the means-plus-function limitations of claim 7 (e.g., sensing current, comparing to a reference, modulating a drive signal), the specific corresponding structures from the ’890 patent are made obvious by the combination. The TI Book discloses PWM controller ICs like the UCC2813—the same type cited in the ’890 patent—which contain the requisite internal reference and op-amp structures. Hamp discloses various DC-DC converter topologies (e.g., buck, boost) that correspond to the claimed "means for supplying power."
- Motivation to Combine (for §103 grounds): A POSITA would combine Biebl’s driver with a controller from the TI Book to reduce parts count and improve performance, a known design goal. A POSITA would also incorporate a power supply topology from Hamp into Biebl’s circuit to provide an efficient DC-DC converter, fulfilling a desire for efficiency explicitly stated in both references.
- Expectation of Success (for §103 grounds): Combining these standard, well-documented components for their intended purposes would be a straightforward implementation yielding the predictable result of an efficient, regulated LED driver.

Prior Art Relied Upon: Hamp (Application # 2001/0033503) and LT1613 (Linear Technology LT1613 Data Sheet, 1997).
Core Argument for this Ground:
- Prior Art Mapping: This ground presents an alternative theory with Hamp as the primary reference. Petitioner asserted Hamp discloses a DC-DC converter system for driving an LED load and explicitly identifies the LT1613 chip as its PWM controller. The LT1613 data sheet, in turn, discloses the specific internal structures corresponding to the means-plus-function limitations of claim 7, including a bandgap reference core ("means for generating a reference signal") and an internal op-amp ("means for comparing").
- Motivation to Combine (for §103 grounds): The motivation is explicit, as Hamp directly incorporates the LT1613 chip, which would have led a POSITA directly to the LT1613 data sheet for implementation details and structural information.
- Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success because the combination involves implementing a circuit using the very component specified in the primary reference, according to that component's own data sheet.
Additional Grounds: Petitioner asserted an additional challenge (Ground 4) that claim 14 is obvious over Hamp in view of LT1613 and Biebl, relying on a similar combination theory but incorporating Biebl's inoperability detection feature.

"means for sensing current..." (Claim 7): Petitioner proposed the corresponding structure is the set of resistors (e.g., R1A1, R1A2, R1A3) disclosed in the ’890 patent specification that are used for LED current sensing.
"means for generating a reference signal" (Claim 7): Petitioner identified the corresponding structure as the internal reference within a specified PWM control IC, such as a Unitrode UCC2813-3, as disclosed in the patent.
"means for comparing the sensed current signal..." (Claim 7): Petitioner identified the corresponding structure as the internal op-amp within the same disclosed PWM control IC.
"means for indicating the LED array is inoperable" (Claims 14, 22, 30): Petitioner construed this term’s function as "providing a signal to alert an individual that the LED array is burnt out or disconnected." The corresponding structure was identified as the second op-amp 122 and BULB OUT signal 124 shown in the patent’s figures.

Petitioner argued that discretionary denial under §314(a) would be inappropriate. The petition contended that this was the first IPR filed by Feit Electric against the ’890 patent. It further noted that a prior IPR filed by a different petitioner did not use the same prior art combinations against the challenged claims, presenting new patentability issues for the Board to consider.

Petitioner requests institution of an inter partes review and cancellation of claims 1, 7, 14, 22, and 30 of Patent 6,586,890 as unpatentable.