PTAB

IPR2021-00777

NOCO Co v. Pilot Inc

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1. Case Identification

2. Patent Overview

  • Title: AUTOMOBILE CHARGER
  • Brief Description: The ’653 patent discloses an automobile charger for jump-starting a vehicle. The system uses a microcontroller, power converter, and various detectors to monitor battery levels and load connections, selectively connecting a jump starter battery to a vehicle battery based on determined conditions.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 7-9, 11-12, 14-18, and 20 under §102

  • Prior Art Relied Upon: Richardson (Application # 2009/0174362).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Richardson discloses every limitation of independent claims 7 and 17, and their respective dependent claims. Richardson’s jump-starting apparatus was asserted to teach the claimed “charging device” comprising a “battery level detector” (Richardson’s “battery voltage sensor”), a “load detector” (Richardson’s “reverse voltage sensor”), a microcontroller, and “switching circuitry” (Richardson’s “contact relay”). Petitioner mapped how Richardson’s microcontroller receives inputs on battery level and load connection type, generates an output signal, and uses that signal to control the relay, thereby selectively connecting the jump starter battery to the vehicle load, as required by the claims.

Ground 2: Obviousness of Claims 1 and 3-6 under §103

  • Prior Art Relied Upon: Richardson (Application # 2009/0174362) and Krieger (Patent 7,345,450).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Richardson teaches most elements of independent claim 1, which recites specific electrical connections between the charger’s components. The key difference identified was that Richardson places its switching circuit on the positive side of the battery-to-load connection, while the connections recited in claim 1 are consistent with a switching circuit placed on the negative side. Krieger was introduced as a secondary reference because it explicitly discloses a microprocessor-controlled jump starter with its switching circuit (a solid-state switch) on the negative side of the connection.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to modify Richardson’s system with Krieger’s negative-side switch placement. Petitioner argued that placing the switch on either the positive or negative side represents one of only two fundamental design choices. A POSITA would be motivated to select the negative-side configuration, as taught by Krieger, because it is a common and well-known safety practice in the automotive industry to connect the negative terminal last to prevent dangerous sparks near the battery.
    • Expectation of Success: The proposed combination involved substituting a known switching configuration into a conventional jump-starter circuit. Petitioner argued this was a simple and predictable modification that a POSITA would have undertaken with a high expectation of success.

Ground 3: Obviousness of Claims 1 and 3-6 under §103

  • Prior Art Relied Upon: Baxter (Application # 2010/0173182) and Krieger (Patent 7,345,450).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative obviousness challenge to the same set of claims as the previous ground. Petitioner argued that Baxter discloses a safety circuit for jump-starting that, like Richardson, teaches most elements of claim 1. However, Baxter also places its switching circuit (a set of MOSFETs) on the positive side of the load connection. Krieger was again cited for its explicit teaching of placing the switching circuit on the negative side.
    • Motivation to Combine: The motivation to combine Baxter and Krieger was asserted to be identical to the motivation for combining Richardson and Krieger. A POSITA would have recognized the safety benefits of a negative-side switch, as taught by Krieger and widely practiced in the industry, and would have been motivated to apply this known design principle to Baxter’s system.
    • Expectation of Success: Petitioner asserted that modifying Baxter's circuit by relocating the switch based on Krieger's teaching was a straightforward and predictable design choice for a POSITA.

  • Additional Grounds: Petitioner asserted additional challenges, including that claims 7-9, 11, 12, 14-18, and 20 are anticipated by Baxter, and that claim 13 is obvious over Richardson in view of George (Patent 6,803,743).

4. Key Claim Construction Positions

  • "conducts power supply or power outage for the load through the microprocessor" (Claim 3): Petitioner argued that the plain meaning of this term requires the high current used for jump-starting to literally pass through the microprocessor integrated circuit. Petitioner strategically conceded that if the Board adopts this construction, claim 3 would not be invalid over the asserted prior art. However, if the Board adopts the Patent Owner’s competing construction from district court litigation ("the switching circuit connects power... under the control of the microcontroller"), Petitioner maintained that claim 3 is obvious.
  • "recharging level" (Claims 12 and 13): Petitioner proposed this term be construed to mean "the level of the first battery after it is connected to the load." This construction was based on the patent’s specification, which describes detecting an "abnormal voltage" generated by the vehicle’s alternator after a successful start. This elevated voltage serves as the trigger for the control module to disconnect the jump starter, protecting it from damage.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1, 3-9, 11-18, and 20 of the ’653 patent as unpatentable.