PTAB

IPR2019-00622

Huawei Technologies Co Ltd v. Maxell Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Information Recording Medium, Enclosing Casing of Information Recording Medium, and Information Recording Apparatus Using the Same
  • Brief Description: The ’068 patent describes a method for recording data on an information recording medium, such as an optical disc. The invention's purported solution is to prevent data loss from unexpected power interruptions by detecting when the electric power supplied from a battery decreases and, in response, writing "intermediate" managing information to the disc to allow for proper finalization later.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 2 are anticipated by Obata

  • Prior Art Relied Upon: Obata (Japanese Patent Publication No. H05-054517A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Obata discloses every limitation of claims 1 and 2. Obata describes a battery-powered optical disc recording device that addresses the same problem as the ’068 patent: potential data loss if a recording session is interrupted by power loss before a table of contents (TOC) is written. Obata's device monitors the battery's voltage and, upon detecting a drop below a predetermined threshold, it "forcibly" records the TOC information to the disc. Petitioner asserted that this voltage detection directly corresponds to the claimed step of detecting when "electric power supplied from a battery...decreases." The recorded TOC in Obata was argued to be the claimed "managing information" utilized for managing the recorded data.
    • Key Aspects: The core of the argument is that Obata's system for preserving data integrity in the face of battery depletion is functionally identical to the method claimed in the ’068 patent.

Ground 2: Claims 1 and 2 are anticipated by Katai

  • Prior Art Relied Upon: Katai (Japanese Patent Publication No. H08-249789A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Katai also anticipates all limitations of the challenged claims. Katai teaches a battery-powered recording device that monitors battery voltage to detect when capacity is insufficient. To prevent false positives from momentary voltage dips at the start of intermittent recording, Katai's system requires at least two consecutive voltage samples to fall below a threshold (Vth). Once this condition is met, the device records a user table of contents (U-TOC) to the disc and stops the recording operation. Petitioner mapped Katai’s U-TOC to the claimed "managing information" and argued its voltage-checking logic met the claim limitation of detecting a decrease in electric power below a predetermined level before recording that information.

Ground 3: Claims 1 and 2 are obvious over Obata in view of Clegg

  • Prior Art Relied Upon: Obata (Japanese Patent Publication No. H05-054517A) and Clegg (Patent 5,394,089).

  • Core Argument for this Ground:

    • Prior Art Mapping: As an alternative to anticipation, Petitioner argued that if Obata's voltage detection were not deemed to explicitly disclose the claimed "power" decrease detection, the combination with Clegg would render it obvious. Obata provides the base system of a battery-powered recorder that writes a TOC upon detecting a low battery condition. Clegg teaches a sophisticated battery monitoring system that measures both instantaneous current and voltage to compute the "instantaneous power delivered by the battery."
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Clegg’s direct power monitoring system with Obata's recording device for predictable benefits. The primary motivation was to more accurately and reliably detect when the battery was truly depleted, thereby ensuring the TOC was written at the optimal time—not so early as to prematurely end a recording session, and not too late to risk data loss. This was framed as the simple application of a known, improved monitoring technique (Clegg) to a known system ready for improvement (Obata).
    • Expectation of Success: A POSITA would have had a high expectation of success, as combining known electronic monitoring circuits and recording systems was routine in the art.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1 and 2 are obvious over Obata alone (Ground 2), over Katai alone (Ground 5), and over Katai in view of Clegg (Ground 6), relying on similar technical principles and motivations.

4. Key Technical Contentions (Beyond Claim Construction)

  • Voltage as a Proxy for Power: A central technical contention across multiple grounds was that, for a battery-powered device with a relatively stable load, a decrease in battery voltage is directly proportional to a decrease in the power it supplies. Petitioner argued a POSITA would have inherently understood this basic electrical principle. Therefore, prior art references like Obata and Katai, which explicitly teach detecting a voltage drop below a threshold, were argued to either directly disclose or render obvious the claimed limitation of detecting a power decrease below a predetermined level.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) of claims 1 and 2 of the ’068 patent and a final written decision finding those claims unpatentable and ordering their cancellation.