PTAB

IPR2021-00374

Carjamz com Inc v. Putco Inc

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1. Case Identification

2. Patent Overview

  • Title: LED Lamp with a Flexible Heat Sink
  • Brief Description: The ’796 patent discloses a light-emitting diode (LED) lamp, primarily for automotive use, that employs a flexible heat sink made of a braided metal fabric. This design is intended to dissipate heat from the LEDs without requiring a fan or a large, rigid heat sink body, allowing for installation in confined spaces.

3. Grounds for Unpatentability

Ground 1: Claims 1-17 are obvious over the '529 patent in view of Kushalappa and Nepple.

  • Prior Art Relied Upon: Taiwan Patent No. M501529 (’529 patent), Kushalappa (Application # 2014/0063829), and Nepple (Patent 8,746,927).
  • Core Argument for this Ground: Petitioner argued that the ’529 patent discloses an LED lamp structure for automotive use that is virtually identical to that claimed in the ’796 patent. Kushalappa and Nepple were asserted to supply teachings for specific, well-known implementation details, rendering the final combination obvious to a person of ordinary skill in the art (POSITA).
    • Prior Art Mapping:
      • Petitioner contended that the primary reference, the ’529 patent, discloses the core elements of independent claim 1: an LED lamp with a wire harness, a heat conducting member (described as a copper bar), and a flexible heat sink ("metal woven meshes") mechanically connected to the conducting member. The ’529 patent’s figures were argued to show circuit boards mounted on opposite sides of the heat conductor. For method claim 15, the ’529 patent was said to disclose the steps of installing such a lamp and shaping the flexible heat sink to fit within a vehicle.
      • Kushalappa was cited to teach that mounting LEDs on a printed circuit board (PCB) was a common and obvious design choice. Kushalappa also explicitly disclosed using a flexible connector made of braided copper and securing components with heat-conducting adhesive, allegedly rendering claims dependent on these features obvious.
      • Nepple was introduced to address claim 6, which requires "tinned copper strands." Petitioner argued Nepple explicitly teaches that a flexible heat sink may be a braided copper cable that is tin-plated, making this material choice an obvious variant.
    • Motivation to Combine: A POSITA would combine these references to leverage known solutions for known problems. For example, a POSITA would be motivated to mount the LEDs of the ’529 patent lamp onto a standard PCB, as taught by Kushalappa, for manufacturing efficiency and reliability. Similarly, selecting specific, advantageous materials for the flexible heat sink, such as braided copper (Kushalappa) or tinned copper (Nepple), was presented as a routine design choice to achieve the known goal of effective heat dissipation.
    • Expectation of Success: Petitioner asserted a POSITA would have had a high expectation of success, as the combination merely involved applying conventional components (PCBs, adhesives) and known materials (braided or tinned copper) to the lamp structure of the ’529 patent, with each element performing its expected function in a predictable manner.

Ground 2: Claims 1-17 are obvious over the '921 application in view of Kushalappa and Nepple.

  • Prior Art Relied Upon: Japanese Laid-open Application No. JP 2015-85921 (’921 application), Kushalappa (Application # 2014/0063829), and Nepple (Patent 8,746,927).
  • Core Argument for this Ground: This ground presented an alternative primary reference, the ’921 application, which also disclosed the fundamental features of the claimed invention. As in Ground 1, Kushalappa and Nepple were relied upon to demonstrate the obviousness of specific features not explicitly detailed in the primary reference.
    • Prior Art Mapping:
      • The ’921 application, directed to a motorcycle headlight unit, was argued to teach an LED lamp with a heat conducting member (a copper "heat pipe") and a flexible heat sink made from a "woven sheet of copper wire" formed into loops or bands. The reference showed LED substrates mounted on opposite sides of the heat pipe and included a mounting base, allegedly disclosing the core limitations of the challenged claims.
      • The incremental teachings of Kushalappa and Nepple served the same purpose as in Ground 1. Kushalappa was used to support the argument that using a PCB as the LED substrate would be an obvious choice. It was also cited for its teachings on using thermal adhesive and braided copper.
      • Nepple was again relied upon to supply the specific teaching of using tinned copper for the braided metal bands of the flexible heat sink.
    • Motivation to Combine: The motivation was framed as modifying the motorcycle lamp of the ’921 application with conventional automotive lighting technologies. A POSITA would combine the teachings of Kushalappa and Nepple to implement the design using standard components and materials, such as replacing the disclosed substrate with a common PCB or selecting tinned copper for its known properties, to achieve a predictable and reliable result.
    • Expectation of Success: A POSITA would have reasonably expected success in combining these elements because it involved the straightforward substitution of known, interchangeable components into the base design of the ’921 application, leading to a predictable outcome.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of Patent 9243796 as unpatentable.