Cooler Master Co., Ltd. v. Aavid Thermalloy LLC

1. Case Identification

• Patent #: 7,100,679
• Filed: November 14, 2018
• Petitioner(s): Cooler Master Co., Ltd.
• Patent Owner(s): Aavid Thermalloy LLC.
• Challenged Claims: 1, 2, 4, 5

2. Patent Overview

• Title: Integrated Circuit Heat Pipe Heat Spreader with Through Mounting Holes
• Brief Description: The ’679 patent discloses a heat pipe for cooling electronic components, featuring a sealed vapor chamber formed by two plates. The invention focuses on creating through-holes for mounting fasteners that pass through the device without compromising the sealed integrity of the vapor chamber.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, and 5 are obvious over Morikawa in view of Nakamura

• Prior Art Relied Upon: Morikawa (Japanese Examined Utility Model Application Publication No. S53-32387 Y) and Nakamura (Japanese Unexamined Utility Model Application Publication No. S50-55262).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Morikawa teaches the majority of limitations in independent claim 1, including a heat pipe with a sealed vapor chamber formed by spaced-apart plates and internal metal pipes that function as "spacers" to create isolated through-holes for mounting. Petitioner asserted that Nakamura supplies the key missing element: a "depression formed in said first plate which...is bonded to said second plate." Nakamura discloses a "concavity" (element 9) formed in one plate and bonded to an opposing plate to create a robust, sealed mounting point, which Petitioner contended corresponds directly to the claimed depression.
  • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine the references as they address the same technical problem in analogous art. Critically, Petitioner argued that Nakamura provides an express motivation to combine because it explicitly identifies a prior art patent corresponding to Morikawa, describes its manufacturing shortcomings, and proposes its "concavity" design as a direct improvement.
  • Expectation of Success: Given Nakamura's direct teaching to solve a known problem in a Morikawa-type design, a POSITA would have had a high and reasonable expectation of success in combining the teachings to create a more reliable and easily manufactured heat pipe.

Ground 2: Claim 5 is obvious over Morikawa in view of Nakamura and further in view of Takahashi

• Prior Art Relied Upon: Morikawa, Nakamura, and Takahashi (Japanese Examined Utility Model Application Publication No. H8-10205).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted this three-way combination renders claim 5 obvious. Claim 5 adds the limitation that the first and second plates each include a peripheral lip located at an edge of said boundary structure which are bonded together. Petitioner contended that Morikawa's base design, which joins plates perpendicularly at their edges, is difficult to manufacture. The asserted role of Takahashi is to teach an improved bonding structure. Takahashi discloses using outwardly extending "flanges (17)" on its plate members, which Petitioner argued are the claimed "lips," allowing for easier and more reliable parallel bonding (e.g., via brazing).
  • Motivation to Combine: A POSITA seeking to improve the manufacturability and seal quality of the Morikawa/Nakamura device would be motivated to look to analogous art like Takahashi. Takahashi's flange design provides a clear solution to the difficult perpendicular bonding taught by Morikawa. A POSITA would therefore incorporate Takahashi's flanges onto the device of Morikawa/Nakamura to simplify manufacturing and improve the peripheral seal.
  • Expectation of Success: Petitioner argued that applying a standard, well-known flange sealing technique from Takahashi to the device of Morikawa/Nakamura would be a predictable modification with a high expectation of success, resulting in a better-bonded sealed edge.

4. Key Claim Construction Positions

• "Spacer": Petitioner argued for the construction "structure used to maintain a space or clearance between the plates." This opposes the Patent Owner's narrower construction from related litigation, which required the spacer to be separate from the claimed "depression" and to provide support for a capillary wick. Petitioner cited the ’679 patent's specification, which states spacers can be "embossed depressions," and argued that wicks (and the capillary forces they provide) are optional features in heat pipes.
• "Vapor Chamber": Petitioner proposed the construction "enclosed and hermetically sealed void or cavity in which a working fluid is present..." Petitioner argued this is more precise than the Patent Owner's proposed "vacuum sealed chamber" and correctly omits the additional, unsupported limitation that "capillary forces are utilized." Petitioner contended that the use of capillary forces is an optional, not required, feature of the claimed invention.
• "Lip": Petitioner argued for the construction "portion of the plate comprising a region bonded to another plate." This counters the Patent Owner's proposed construction requiring the lip to be a portion of the plate's "inner or interior surface." Petitioner contended the Patent Owner's construction is physically contradictory, as a region bonded to another plate is at the boundary of the chamber and can no longer be considered an "inner or interior" surface of the sealed void.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. § 325(d). It asserted that the primary references (Morikawa, Nakamura, and Takahashi) were not before the Examiner during the original prosecution. Furthermore, Petitioner contended this petition is not redundant of a previously filed petition because it relies on a new primary reference (Morikawa) and, consequently, presents substantially different arguments regarding key claim limitations like "spacer." This distinguishes it from the prior petition, which had used Nakamura as the primary reference.

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1, 2, 4, and 5 of Patent 7,100,679 as unpatentable.