Cooler Master Co Ltd v. Aavid Thermalloy LLC

1. Case Identification

• Case #: IPR2019-00144
• Patent #: 7,066,240
• Filed: October 31, 2018
• Petitioner(s): Cooler Master Co., Ltd.
• Patent Owner(s): Aavid Thermalloy LLC.
• Challenged Claims: 9-13

2. Patent Overview

• Title: Integrated Circuit Heat Pipe Heat Spreader with Through Mounting Holes
• Brief Description: The ’240 patent relates to heat pipes, also known as vapor chambers, designed with integrated mounting holes for attaching them to heat-generating components. The invention describes forming these holes using structures like "hollow columns" or "depressions" that pass through the device without compromising the sealed integrity of the internal vapor chamber.

3. Grounds for Unpatentability

Ground 1: Claims 9-13 are obvious over Nakamura.

• Prior Art Relied Upon: Nakamura (Japanese Unexamined Utility Model Application Publication, 1975).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Nakamura, a 1975 publication concerning heat pipes with mounting holes, discloses all elements of the challenged claims. Petitioner asserted that Nakamura’s "sealed container" (element 7) teaches the claimed "boundary structure" that defines an enclosed "vapor chamber." Critically, it was argued that Nakamura’s "concavity" (element 9) is structurally equivalent to the ’240 patent’s "hollow column" or "depression." This concavity is formed in one plate, projects into the vapor chamber, and is bonded to the opposing plate to create a mounting hole (element 11) that is isolated from the internal chamber. Petitioner further asserted that Nakamura’s disclosure of a wick (element 8) satisfies the limitations of dependent claim 10.

Ground 2: Claims 9-13 are obvious over Nakamura in view of Takahashi.

• Prior Art Relied Upon: Nakamura (Japanese Unexamined Utility Model Application Publication, 1975) and Takahashi (Japanese Examined Utility Model Application Publication, 1991).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative, primarily addressing the "peripheral lip" limitation recited in independent claims 11, 12, and 13. While arguing that Nakamura inherently disclosed a sealed periphery, Petitioner asserted that Takahashi explicitly teaches this feature. Takahashi describes forming a sealed container by joining "flanges" (element 17) located at the periphery of its two plate members using a vacuum brazing method. Petitioner contended that these flanges directly correspond to the claimed "peripheral lip" that is sealingly bonded to form the boundary structure.
  • Motivation to Combine: A POSITA would combine the references because they are analogous art, both addressing the problem of mounting heat pipes. Both also disclose similar manufacturing techniques, including pressing and brazing. Petitioner argued a POSITA would be motivated to incorporate Takahashi's explicit peripheral flange design into Nakamura’s device to achieve a more robust and easily manufactured peripheral seal, which would have been a predictable improvement.
  • Expectation of Success: The combination of Takahashi’s well-known flange sealing method with Nakamura’s overall heat pipe design was presented as a straightforward application of known engineering principles, yielding predictable results with a high expectation of success.

4. Key Claim Construction Positions

• "Vapor Chamber": Petitioner proposed construing this term as an "enclosed and sealed space or cavity in which a heat transfer fluid is present to be evaporated...and condensed to transport or spread heat." This construction was argued to be critical for two reasons. First, it avoids the Patent Owner’s ambiguous term "vacuum sealed." Second, it omits the requirement that "capillary forces are utilized," which Petitioner contended was an optional feature tied to the presence of a wick and was being improperly imported from the specification into the independent claims.
• "Lip": Petitioner proposed the construction "portion of the plate comprising a region bonded to another plate." This was presented as a broader, more reasonable interpretation than the Patent Owner's proposed construction, which Petitioner argued was self-contradictory by requiring the bonded region to be part of the plate's "inner or interior surface"—a location that is no longer "inside" the heat pipe once bonded.
• "Hollow Column": Petitioner adopted the Patent Owner's proposed construction for purposes of the petition: "a columnar structure defining an unfilled or empty space."

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. §325(d) by emphasizing that none of the prior art references relied upon in the petition (Nakamura and Takahashi) were cited or considered during the original prosecution of the ’240 patent. Consequently, Petitioner contended that the petition presented new art and novel grounds of unpatentability that had not been previously evaluated by the USPTO.

6. Relief Requested

• Petitioner requests institution of an inter partes review for claims 9-13 and cancellation of those claims as unpatentable.