PTAB

IPR2020-00208

MaxLite Inc v. Jiaxing Super Lighting Electric Appliance Co Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: LED Tube Lamp
  • Brief Description: The ’826 patent describes an LED tube lamp designed to replace fluorescent lamps. The core technology involves circuitry that allows the lamp to operate with different power sources, such as a high-frequency electronic ballast or a low-frequency magnetic ballast, by using a mode determination circuit and a mode switching circuit to select between different driving modes.

3. Grounds for Unpatentability

Ground 1: Anticipation by Duan - Claims 1, 7, and 12-18 are anticipated under 35 U.S.C. §102 by Duan.

  • Prior Art Relied Upon: Duan (CN Patent No. 204442771U).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Duan discloses every limitation of the challenged claims. Duan describes an LED tube lamp that can be used with high-frequency electronic ballasts, low-frequency magnetic ballasts, or no ballast without changing the circuit architecture. Petitioner contended this functionality mirrors the invention of the ’826 patent.
      • Independent Claim 1: Petitioner mapped each element of claim 1 to Duan’s disclosures. Duan’s “rectifier filtering circuit,” “DC to DC conversion circuit,” “LED light strip,” and “frequency selecting circuit” were argued to teach the claimed first and second rectifying circuits, filtering circuit, LED lighting module, mode determination circuit, and mode switching circuit. Critically, Petitioner asserted that Duan’s system operates in two distinct driving modes based on the input power frequency. In a low-frequency mode, current flows through the full DC-to-DC conversion circuit. In a high-frequency mode, a transistor switch is activated, causing the current to bypass components of the DC-to-DC conversion circuit. This directly corresponds to limitation 1[g], which requires a first driving mode where the filtered signal drives the LED module and a second mode where the signal bypasses at least a component of the driving circuit.
      • Dependent Claims 7, 12-18: Petitioner argued that Duan’s disclosures anticipate the dependent claims. For claim 7, Duan’s frequency selecting circuit was shown to generate a result signal based on whether the external signal is above a defined frequency cutoff. For claims 12-18, Petitioner asserted that Duan’s DC-to-DC conversion circuit is disclosed as a standard buck converter, which inherently includes the “controller,” “switching circuit” (MOSFET), and “energy storage circuit” (inductor and diode in series) recited in these claims. Further limitations, such as the controller's function and the use of a capacitive filter, were also mapped to standard components and configurations within Duan’s detailed circuit diagrams.
    • Key Aspects: A central element of Petitioner's argument was that the ’826 patent is not entitled to any priority date earlier than its filing date of March 25, 2016. Petitioner alleged that the claimed "mode determination circuit" was new matter not present in the parent '630 application or any foreign priority documents. This assertion makes Duan, which has a 2015 issue date, valid prior art against all challenged claims.

4. Key Claim Construction Positions

  • “coupled to”: Petitioner argued this term is explicitly defined in the ’826 patent’s specification to mean "directly connected or coupled to, or on the other element or intervening elements may be present." This broad construction was central to Petitioner's anticipation argument, as it allowed them to assert that components in Duan’s circuit diagrams were "coupled" as required by the claims, even if other circuit elements were physically located between them.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1, 7, and 12-18 of the ’826 patent as unpatentable.