PTAB

IPR2018-01153

Intel Corp v. Qualcomm Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Techniques for Efficiently Generating a Power Supply for a Power Amplifier
  • Brief Description: The ’558 patent discloses an apparatus for generating a power supply signal for a radio frequency (RF) power amplifier in a wireless device. The technology involves a hybrid supply generator that combines a high-efficiency switcher with a high-bandwidth envelope amplifier, and purports to improve efficiency by connecting a boost converter to supply a higher voltage only to the envelope amplifier when needed.

3. Grounds for Unpatentability

Ground 1: Claims 6 and 8 are obvious over Chu in view of Choi 2010.

  • Prior Art Relied Upon: Chu (a 2008 IEEE journal article) and Choi 2010 (a 2010 IEEE conference paper).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that Chu, which was not considered during prosecution, discloses a hybrid supply generator for a power amplifier with the core components required by the claims, including an envelope amplifier comprising an operational amplifier, a driver, and PMOS/NMOS transistors. However, Chu powers its envelope amplifier directly from a battery. Petitioner asserted that Choi 2010 explicitly teaches adding a boost converter to a similar hybrid supply modulator to provide a stable, boosted voltage to the envelope amplifier, particularly to counteract battery depletion. The combination of Chu’s architecture with Choi’s boost converter was argued to render all limitations of claims 6 and 8 obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Chu and Choi to solve the well-known problem of signal distortion and performance degradation as a device’s battery voltage drops. Choi teaches that using a boost converter provides robust operation despite battery depletion. Petitioner noted that both references are from the same field of hybrid power supply modulators and that Choi even cites Chu as prior art, making the combination a logical and predictable design modification.
    • Expectation of Success: The combination involved applying a known solution (Choi's boost converter) to a known system (Chu's amplifier) to achieve the predictable result of stable operation, especially at low battery voltages.

Ground 2: Claims 1-9 are obvious over Chu in view of Choi 2010 and Myers.

  • Prior Art Relied Upon: Chu, Choi 2010, and Myers (Patent 5,929,702).
  • Core Argument:
    • Prior Art Mapping: This ground builds upon the Chu and Choi combination by adding the teachings of Myers. Petitioner contended that claims 1-5, 7, and 9 require the capability to selectively power the envelope amplifier from either a first supply voltage (e.g., battery) or a boosted supply voltage. While the Chu and Choi combination provides the necessary boosted voltage, Myers discloses a power supply modulator that efficiently selects between multiple different power sources based on the amplitude of the input signal. Petitioner argued that incorporating Myers’s selection functionality into the Chu/Choi system would result in a supply generator that meets all limitations of claims 1-9.
    • Motivation to Combine: A POSITA would be motivated to add the selection capability taught by Myers to the Chu/Choi design to further improve power efficiency and extend battery life, a primary objective in wireless device design. Myers expressly teaches that selecting a power source close to the required output voltage avoids wasting power. This would allow the modified Chu amplifier to use the more efficient battery voltage when sufficient, and only engage the power-consuming boosted voltage when necessary, such as when the battery level is low or a high-amplitude signal requires it.
    • Expectation of Success: Petitioner asserted there would be a high expectation of success, as implementing a selection circuit to switch between two known voltage sources (battery and boosted) was a routine design task for a POSITA. The result—improved efficiency—was predictable and explicitly taught by Myers.

4. Key Claim Construction Positions

  • "envelope signal" (claims 1, 6-8): Petitioner argued that the claims are unpatentable even under the construction proposed by the Patent Owner in parallel litigation, which defines the term as "signal indicative of the upper bound of the output RF signal." Petitioner noted this construction is narrower than the broadest reasonable interpretation but adopted it for the purposes of the petition to demonstrate invalidity even under a patentee-favorable reading.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-9 of the ’558 patent as unpatentable under 35 U.S.C. § 103.