Samsung Electronics Co Ltd v. NuCurrent Inc

1. Case Identification

• Patent #: 9,300,046
• Filed: March 22, 2019
• Petitioner(s): Samsung Electronics Co., LTD.
• Patent Owner(s): Nucurrent, Inc.
• Challenged Claims: 1-3, 5-8, 10, 12, 13, 15-21, and 23-29

2. Patent Overview

• Title: Method for Manufacture of Multi-Layer-Multi-Turn High Efficiency Inductors
• Brief Description: The ’046 patent describes methods for manufacturing high-efficiency inductors for use in electrical circuits, particularly those operating at radio frequencies. The invention aims to reduce resistance loss by employing a multi-layer wire configuration with parallel-connected conductor layers separated by insulator layers.

3. Grounds for Unpatentability

Ground 1: Anticipation over Lee - Claims 1-3, 5-8, 10, 15-21, and 23-29 are anticipated under 35 U.S.C. §102 by Lee.

• Prior Art Relied Upon: Lee (Application # 2007/0267718).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Lee discloses a multi-layer winding inductor that anticipates every element of the challenged claims. Lee describes an inductor with multiple, overlapping looped conductive traces (e.g., traces 311) separated by dielectric insulator layers (e.g., layer 308). Petitioner contended that Lee’s conductive plugs (e.g., plugs 315) meet the limitation of “at least two connectors” that connect the first and second conductor layers in an electrically parallel connection. Furthermore, Petitioner argued that several limitations, such as the generation of a magnetic flux upon a change in electrical current (claim 1(d)), are inherent physical properties of any inductor, including the one disclosed in Lee, which is described for use in radio frequency (RF) integrated circuits where current necessarily changes.
  • Key Aspects: Petitioner argued that Lee’s disclosure of using copper for its conductive traces inherently teaches the use of a thermally conductive material (claim 15) and that its conductive plugs function as the claimed “vias” (claim 16). For dependent claims related to specific dimensions (e.g., claims 5-7), Petitioner contended that Lee’s inductor, designed for RF bands, would operate at frequencies where its disclosed conductor thickness of 0.53 µm would align with the claimed skin depth ratios.

Ground 2: Obviousness over Lee and Alldred - Claims 1-3, 6-8, 10, 15-21, and 23-29 are obvious over Lee in view of Alldred.

• Prior Art Relied Upon: Lee (Application # 2007/0267718) and Alldred (“A 1.2 V, 60 GHz radio receiver with onchip transformers and inductors in 90 nm CMOS,” Nov. 2006).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that while Lee teaches the manufacture of on-chip inductors for RF applications generally, it does not detail a specific RF circuit. Alldred was asserted to supply this teaching by disclosing a 60-GHz radio receiver that explicitly uses on-chip inductors within its low-noise amplifier (LNA) and mixer circuits. The combination of Lee’s manufacturing method with Alldred’s specific RF circuit application would render the claims obvious. This combination explicitly teaches connecting the inductor within an electrical circuit operating above 100 kHz (claim 20) and shows an example of an amplifying circuit (claim 21).
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references because they are complementary. Lee provides the "how-to" for making an on-chip inductor, and Alldred provides a concrete example of "where" and "how" such an inductor would be used in a modern RF circuit. Combining them would be an advantageous and predictable implementation to create a functional, compact RF system.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in implementing Lee’s on-chip inductor within a circuit like Alldred’s. The combination involves applying a known component (Lee's inductor) into a known circuit type (Alldred's RF receiver) to achieve the predictable benefits of on-chip integration, such as reduced size and tighter tolerances.

• Additional Grounds: Petitioner asserted numerous other obviousness grounds that build upon the Lee reference. These grounds argue that it would have been obvious to modify Lee's inductor based on well-known principles or teachings from other secondary references. Key combinations included:

  • Lee in view of Ahn (Patent 7,030,725): To establish the obviousness of an insulator layer thickness less than 5 cm (claim 12), as Ahn teaches specific micron-range thicknesses for insulating layers in similar semiconductor inductors.
  • Lee in view of Kyriazidou (Patent 7,236,080): To establish the obviousness of an inductor quality (Q) factor greater than 5 (claim 13), as Kyriazidou teaches that on-chip inductors in RF circuits typically have a Q-factor in the range of 5 to 10 and that a higher Q-factor is desirable.
  • Lee in view of Partovi (Application # 2009/0096413): To establish the obviousness of connecting a control circuit to the inductor (claim 23), as Partovi discloses an inductive charging system where a microcontroller unit (MCU) controls an inductor in an RF circuit.
  • Lee in view of Hu (an 2001 IEEE article): To establish the obviousness of conductor thickness relative to skin depth (claims 5-7), as Hu teaches that for minimum AC resistance, conductor thickness should be one to two times the skin depth.
  • Petitioner also asserted three-way combinations (e.g., Lee, Alldred, and Ahn) to address the same claim limitations in the context of the Lee-Alldred framework.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5-8, 10, 12, 13, 15-21, and 23-29 of the ’046 patent as unpatentable.