PTAB

IPR2021-00389

Samsung Electronics Co Ltd v. Garrity Power Services LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Bidirectional Wireless Power Transmission
  • Brief Description: The ’067 patent describes an apparatus and system for bidirectional wireless power transfer, allowing a battery to be both wirelessly charged and discharged. The technology utilizes two magnetically coupled units, each with a magnetic core piecepart and a metallic coil, to form a transformer that operates across an electrically isolating path.

3. Grounds for Unpatentability

Ground 1: Anticipation over Kasar - Claims 1, 2, and 15 are anticipated by Kasar under 35 U.S.C. §102.

  • Prior Art Relied Upon: Kasar (Patent 10,404,089).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kasar discloses every limitation of claims 1, 2, and 15. Kasar describes a first electronic device (e.g., a phone) and a second electronic device that couple for bidirectional wireless power transfer. Petitioner contended that Kasar’s "alignment magnet" surrounded by an "inductive coil" corresponds to the ’067 patent’s "first magnetic core piecepart" and "first metallic coil." The ability of Kasar's devices to both transmit and receive power is mapped to the claimed functionality of a battery being configured to be both charged and discharged. The power transfer occurs across an air gap, which Petitioner asserted meets the limitation of an "electrically isolating path." For dependent claim 2, Petitioner argued Kasar’s disclosure of additional magnets used to align the two devices meets the limitation of alignment via a "permanent magnet."

Ground 2: Obviousness over Kasar and Wildmer - Claims 7, 8, 10, 11, and 16 are obvious over Kasar in view of Wildmer under 35 U.S.C. §103.

  • Prior Art Relied Upon: Kasar (Patent 10,404,089) and Wildmer (Application # 2011/0254377).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Kasar teaches the base system of two wirelessly coupled devices with magnetic cores and coils, as outlined in Ground 1. However, Kasar does not explicitly disclose the claimed "power train" with specific switching circuit topologies. Wildmer was argued to supply these missing elements by teaching a symmetric topology for bidirectional wireless power transfer using full-bridge switching circuits on both sides of the coupled inductors. This architecture from Wildmer was mapped to the "power train" and resonant topology limitations of claims 7 and 16. For claim 8, Wildmer was cited for teaching a controller that selectively switches the power train between full-bridge and half-bridge operation in response to a sensed voltage level to adjust power output. For claim 10, Wildmer was argued to teach using a capacitor to achieve zero-current switching for higher efficiency.
    • Motivation to Combine: A POSITA would combine Wildmer's advanced power train and control circuitry with Kasar's fundamental wireless charging system. The motivation was to improve the efficiency, control, and performance of the bidirectional power transfer, as Wildmer explicitly discusses advantages like lower switching losses.
    • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success because combining known power electronics topologies from Wildmer with the wireless charging interface of Kasar involves the application of established design principles to achieve a predictable improvement in system performance.

Ground 3: Obviousness over Kasar, Jeong, and Sakaguchi - Claim 8 is obvious over Kasar in view of Jeong and Sakaguchi under 35 U.S.C. §103.

  • Prior Art Relied Upon: Kasar (Patent 10,404,089), Jeong (Korean Patent Publication No. KR 20140121200A), and Sakaguchi (Japanese Patent Application Publication No. JP 2006238569A).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative combination for claim 8. Petitioner argued that the combination of Kasar and Jeong (which, like Wildmer, teaches a bidirectional power train with full-bridge switching) discloses the elements of claim 7. Sakaguchi was then added to teach the specific controller limitations of claim 8. Sakaguchi explicitly discloses a resonant power supply with a controller that switches operation between full-bridge and half-bridge modes in response to a detected input voltage falling below a prescribed level.
    • Motivation to Combine: A POSITA, having designed a bidirectional power transfer system based on Kasar and Jeong, would be motivated to incorporate Sakaguchi’s control strategy to solve the common problem of input power supply fluctuation. Sakaguchi's controller provides a method to maintain stable performance and prevent malfunction across a wide range of operating conditions, a clear benefit for any power system.
    • Expectation of Success: Integrating a known control method for voltage regulation (from Sakaguchi) into a power transfer circuit (from Kasar and Jeong) was argued to be a straightforward and predictable design modification for a POSITA.
  • Additional Grounds: Petitioner asserted that claims 3 and 5 are obvious over Kasar alone, arguing it would have been obvious to add a mechanical aligner or cavity. Petitioner also presented an obviousness challenge to claims 7, 10, 11, and 16 based on Kasar in view of Jeong, which relied on a similar power train modification theory as the combination with Wildmer.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. The prior art references relied upon were not considered during the original prosecution of the ’067 patent and were alleged to teach the bidirectional power transfer feature that the Examiner previously found lacking.
  • Regarding potential denial under Fintiv, Petitioner argued that the parallel district court litigation was in its early stages with no trial date set. Crucially, Petitioner stipulated that it would not pursue invalidity in the district court litigation based on any grounds on which the IPR is instituted, thereby eliminating substantive overlap between the proceedings.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5, 7, 8, 10, 11, 15, and 16 of the ’067 patent as unpatentable.