PTAB

IPR2021-00376

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 ’473 patent relates to an L.E.D. lamp designed for automotive use that employs a flexible metal fabric as a heat sink. The technology features a central heat-conducting member that draws thermal energy from L.E.D.s mounted on circuit boards, dissipating the heat through several flexible, braided metal straps attached to the member.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over the ‘529 patent in view of Kushalappa and Nepple.

  • Prior Art Relied Upon: ‘529 patent (Taiwan Patent No. M501529), Kushalappa (Application # 2014/0063829), and Nepple (Patent 8,746,927).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the ‘529 patent discloses a device that is structurally almost identical to the invention of the ’473 patent. Specifically, the ‘529 patent taught an L.E.D. lamp for vehicle use comprising a heat-conducting copper bar, multiple flexible metal heat sinks thermally connected to the bar at a common location, and a wire harness. For claim limitations not explicitly detailed in the ‘529 patent, Petitioner asserted that Kushalappa taught using a printed circuit board (P.C.B.) as a conventional substrate for mounting L.E.D.s. To address the material composition of the heat sink straps, Petitioner cited Nepple, which disclosed that flexible heat sinks could be made from braided copper that is tin-plated to prevent corrosion.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA), starting with the core design of the ‘529 patent, would combine the teachings of Kushalappa and Nepple to arrive at the claimed invention. Petitioner contended it would have been a simple and obvious design choice to mount the L.E.D.s of the ‘529 patent device onto a P.C.B. as taught by Kushalappa, a well-known industry practice. Similarly, a POSITA would be motivated to use tinned copper for the braided heat sinks, as taught by Nepple, to achieve the known benefit of improved corrosion resistance.
    • Expectation of Success: Petitioner asserted that combining these known elements for their intended and well-understood purposes would have yielded predictable results. A POSITA would have had a high expectation of success in creating a durable and effective L.E.D. lamp by integrating a standard P.C.B. and corrosion-resistant materials into the base design of the ‘529 patent.

Ground 2: Claims 1-20 are obvious over the ‘921 application in view of Kushalappa and Nepple.

  • Prior Art Relied Upon: ‘921 application (Japanese Laid-Open Patent Application No. JP 201585921A), Kushalappa (Application # 2014/0063829), and Nepple (Patent 8,746,927).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative primary reference, the ‘921 application, which disclosed a motorcycle headlight unit with key claimed features. Petitioner argued the ‘921 application taught an L.E.D. light source, a copper heat pipe serving as a heat-conducting member, and a flexible heat sink made from a woven sheet of copper wire. The heat sink was shown with two distinct loops attached at a common location, configured to maximize surface area. The incremental teachings were supplied by the same secondary references as in Ground 1: Kushalappa provided the explicit teaching of mounting L.E.D.s on a P.C.B., and Nepple taught the use of tinned copper for flexible heat sinks.
    • Motivation to Combine: The motivation to combine was similar to Ground 1. A POSITA designing an L.E.D. lamp based on the ‘921 application would be motivated to incorporate a P.C.B. for L.E.D. mounting, as it was a common and reliable method disclosed by Kushalappa. To improve the durability of the flexible copper heat sink, a POSITA would have found it obvious to apply tin plating as taught by Nepple. Petitioner also argued that adapting the motorcycle-specific design of the ‘921 application for general automotive use would have been an obvious modification.
    • Expectation of Success: The combination of these established technologies was argued to be entirely predictable. A POSITA would expect that using a P.C.B. and tinned copper would function as intended within the framework of the ‘921 application’s design, resulting in a functionally equivalent L.E.D. lamp with a high degree of certainty.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of Patent 9,995,473 as unpatentable.