PTAB

IPR2020-00944

Shenzhen Carku Technology Co Ltd v. NOCO Co

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1. Case Identification

2. Patent Overview

  • Title: Apparatus for Jump Starting a Vehicle Engine
  • Brief Description: The ’015 patent describes a portable jump starter apparatus for vehicle engines. The claimed invention includes safety features, specifically a vehicle battery isolation sensor to detect a battery's presence and a separate reverse polarity sensor to detect correct terminal connection, where a microcontroller only activates a power switch if both conditions are met.

3. Grounds for Unpatentability

Ground 1: Claims 1, 7-9, 15, and 17-21 are anticipated by Richardson

  • Prior Art Relied Upon: Richardson (Application # 2013/0154543).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Richardson, a portable power source for jump starting engines, discloses every limitation of claim 1. Richardson teaches a system with a "vehicle voltage sensor 30" to detect the presence of a vehicle battery and a separate "reverse voltage sensor 24" to monitor the polarity of the jumper cables. Both sensors provide distinct input signals to a system microcontroller (12). This microcontroller is configured to control a power switch (contact relay 34) such that it is not turned on if the sensors indicate either the absence of a vehicle battery or an improper polarity connection, thereby anticipating the core limitations of claim 1. Petitioner further asserted that Richardson anticipates various dependent claims by disclosing a battery temperature sensor (claim 7), a circuit to measure the internal power supply's voltage (claim 8), a voltage regulator (claim 9), visual indicators for capacity status (claim 15), a reverse polarity warning (claim 17), power status indicators (claim 18), a manual override mode (claims 19-20), and a plug-in jumper cable device (claim 21).

Ground 2: Claims 1, 17, and 21 are anticipated by Klang

  • Prior Art Relied Upon: Klang (Patent 6,424,158).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Klang, a battery charging system, anticipates the key features of claim 1. Klang discloses a diagnostic system with a "voltage sensor 46" to detect the presence of a connected battery and a separate "reverse polarity sensor 48" to detect if the leads are connected backwards. These separate sensors report to a system controller (12), which includes a microprocessor (26). The controller only allows the charging process to proceed (i.e., turns on the power switch) after its start-up logic confirms both the presence of a battery and its proper polarity connection. If the battery is absent or connected in reverse, the controller prevents the power switch from closing. Petitioner also argued Klang anticipates dependent claims by disclosing a visual indicator to warn of reverse polarity (claim 17) and a jumper cable device for connecting to a battery (claim 21).

Ground 3: Claims 2-3, 12-14, and 23 are obvious over Richardson in view of Lei

  • Prior Art Relied Upon: Richardson (Application # 2013/0154543) and Lei (Patent 9,954,391).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that while Richardson discloses the base jump starter of claim 1, Lei teaches the specific features of several dependent claims. Lei, an emergency power source, explicitly teaches using a "battery pack of multiple lithium-ion batteries" due to their light weight and high discharge current, rendering claims 2 and 3 obvious. Lei also discloses an "LED lighting lamp" for outdoor lighting, suggesting the flashlight circuit of claims 12 and 13. Furthermore, Lei teaches using its alerting system to provide a visual alarm in an emergency situation, controlled by an MCU, which would make the feature of claim 14 obvious. Finally, Lei discloses an "insertable anti-reverse connector" dimensioned to fit in an output port in only one orientation, directly teaching the limitation of claim 23.
    • Motivation to Combine: A POSITA would combine Lei's features with Richardson’s jump starter to achieve predictable benefits. Using lithium-ion batteries as taught by Lei would make Richardson’s device lighter and more powerful. Adding common convenience and safety features like an LED flashlight, an emergency alarm, and a keyed connector for fool-proof connection would have been simple and desirable improvements.
    • Expectation of Success: The combination involved applying conventional, well-understood technologies for their intended purposes, leading to a high expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Richardson in view of Krieger, Wanzong, Baxter, Carku Epower brochures, and Richardet, as well as combinations based on Klang in view of Krieger, Richardet, and Lei. These grounds relied on similar theories of combining known features to improve safety or add convenience.

4. Key Claim Construction Positions

  • "reverse polarity sensor" / "vehicle battery isolation sensor": Petitioner proposed, consistent with prior district court orders, that these two terms be construed as sensors that are structurally separate from each other. This construction is critical to the argument that the prior art discloses the allegedly novel feature of the patent: using two distinct sensors to check for battery presence and correct polarity.
  • "input signals from said vehicle isolation sensor and said reverse polarity sensor": Petitioner proposed this phrase means "distinct input signals" from each of the two respective sensors. This reinforces the concept of separate sensing functions providing independent information to the microcontroller, a configuration Petitioner argued was present in the prior art.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-23 of the ’015 patent as unpatentable.