PTAB

IPR2018-01036

TTE Technology Inc v. Interface Linx LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electrical Connector Assembly
  • Brief Description: The ’678 patent describes an electrical connector assembly comprising a plug and a receptacle with a distinct, multi-sided mating shape. The design’s purported purpose was to overcome alleged drawbacks of conventional connectors like USB by using a non-symmetrical shape to ensure proper orientation and prevent mismating.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3 under 35 U.S.C. §102

  • Prior Art Relied Upon: Jones (Patent 4,764,129)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Jones, which was never considered during prosecution, discloses every limitation of claims 1-3. The key features used to overcome rejections during prosecution—specifically (1) the first and second sides being longer than the third sides, (2) the width between the third sides being greater than the width between the fourth sides, and (3) the fourth sides extending obliquely from the second side—are all allegedly present in Embodiment 15 of Jones. Petitioner provided annotated diagrams comparing Jones’s connector shape directly to the ’678 patent’s Figure 10 to demonstrate that Jones’s trapezoidal keyway and overall cross-section meet these limitations.

Ground 2: Obviousness of Claims 1-3 under 35 U.S.C. §103

  • Prior Art Relied Upon: Nishio (Patent 6,322,395) in view of Jones (Patent 4,764,129)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Nishio, a prior art USB connector considered by the Examiner, discloses all elements of the claims except for the "oblique" orientation of the fourth sides. During prosecution, the claims were amended to add this exact limitation to distinguish over Nishio. Petitioner asserted that Jones expressly teaches this missing element by disclosing a connector with a trapezoidal keyway, which by definition has oblique sides, for the purpose of easier mating.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Jones's trapezoidal keying feature with Nishio's standard USB-type connector to improve usability and prevent misalignment, a common goal in the field. Jones explicitly states its invention is applicable to computer-related fields, providing a direct suggestion to apply its teachings to a connector like Nishio.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination merely involves substituting one known mechanical guiding shape (Nishio’s rectangular key) for another (Jones’s trapezoidal key) to achieve the predictable benefit of improved alignment.

Ground 3: Obviousness of Claim 4 under §103

  • Prior Art Relied Upon: Jones (Patent 4,764,129) in view of Koizumi (Patent 5,630,170)

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that dependent claim 4, which adds a specific terminal arrangement for detecting the type of plug connected, is obvious over the basic connector shape of Jones when combined with the teachings of Koizumi. Koizumi, which relates to video game peripherals, explicitly discloses using a specific pin configuration to distinguish between different types of connected devices. It teaches shorting a detecting terminal to a power terminal on the plug side, which interacts with corresponding receptacle terminals to create a detectable signal, mapping directly to the arrangement claimed in claim 4.
    • Motivation to Combine: A POSITA would be motivated to incorporate Koizumi's known terminal detection scheme into the connector of Jones to add the functionality of plug-type identification. This would be a logical and desirable improvement to Jones’s system, which is already focused on preventing plug/socket mismatching, thereby enhancing its error-prevention capabilities.
    • Expectation of Success: Combining a known terminal configuration for device detection with a standard connector housing was a routine design choice in the art. A POSITA would expect this combination to work for its intended purpose with predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness and anticipation challenges, including that claims 1-3 are obvious over Jones alone; claims 1-3 are obvious over Kusagaya in view of Jones; claims 1-3 are anticipated by the RC-5238 industry standard; and claim 5 is obvious over the combination of Jones, Koizumi, and Roldan (which teaches integral stamping of metal terminals).

4. Key Claim Construction Positions

  • "obliquely": Petitioner construed this term to mean "neither parallel nor at a right angle to a specified or implied line; slanting," based on its plain and ordinary meaning. This construction was central to Petitioner's argument that the Examiner allowed the claims for adding a limitation that, while absent in the rectangular Nishio connector, was expressly taught by the trapezoidal keyway in Jones.
  • "angled away from each other": Petitioner construed this phrase, which describes the "fifth sides" of the connector, to include sides that are co-linear and point in opposite directions (i.e., at a 180-degree angle). Petitioner argued this construction is required to cover the patent's own preferred embodiments and is consistent with the Examiner's interpretation of similar structures in the prior art during prosecution.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-5 of Patent 6,508,678 B1 as unpatentable.