PTAB

IPR2021-01196

CoolIT Systems Inc v. Asetek Danmark AS

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cooling System for a Computer System
  • Brief Description: The ’196 discloses a liquid cooling system for a computer, often referred to as an "all-in-one" cooler. The invention centers on an integrated element that combines a heat exchange interface, a reservoir for cooling liquid, and a pump into a single compact unit designed to be mounted on a heat-generating component like a CPU.

3. Grounds for Unpatentability

Ground 1: Obviousness over Duan - Claims 1-4, 6, 7, 9, 16, 17, and 19 are obvious over Duan.

  • Prior Art Relied Upon: Duan (Application # 2006/0185830).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Duan, which discloses a "cooling plate module" for a CPU, teaches every limitation of the challenged claims. Duan's integrally formed liquid driving module and cooling plate constituted the claimed "reservoir." The key components of the pump—including the double-sided chassis (Duan's accommodation chamber 21), impeller (impeller stage 223), stator (coil stage 221), and impeller cover (lower cover 225)—were alleged to be disclosed in a virtually identical arrangement. Petitioner further contended that Duan's liquid inlet 23 meets the limitation of an inlet "below a center of the impeller," and its fluid outlet 24 is positioned tangentially as required.
    • Motivation to Combine (for §103 grounds): As this ground relied on a single reference, Petitioner's position was that Duan alone rendered the claims obvious, essentially presenting an anticipation-style argument under 35 U.S.C. §103.
    • Expectation of Success (for §103 grounds): Not applicable for a single-reference ground.

Ground 2: Obviousness over Duan and Wu - Claims 4, 5, 8, 10-15, and 18 are obvious over Duan in view of Wu.

  • Prior Art Relied Upon: Duan (Application # 2006/0185830), Wu (Patent 6,894,899).
  • Core Argument for this Ground:
    • Prior Art Mapping: To the extent Duan does not explicitly teach certain features, Wu supplied the missing elements. For claim 4, Wu taught making a heat absorption layer from high-conductivity materials like copper. For claim 5, Wu disclosed using mounting legs and a spring retainer to secure a cooling unit to a CPU. For claim 8, Wu described a fan used to direct ambient air across a radiation unit to improve heat dissipation.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Wu's teachings with Duan's system to improve performance and solve known problems in CPU cooling. Both references address integrated liquid cooling systems. A POSITA would be motivated to use copper as taught by Wu for better thermal conductivity and to add a fan to Duan's radiator to increase heat dissipation, which are common and predictable improvements.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as incorporating a fan and using known materials like copper are standard design choices in the field of thermal management for electronics.

Ground 3: Obviousness over Duan and Admitted Prior Art - Claims 5, 8, 10-15, and 18 are obvious over Duan in view of the Admitted Prior Art (APA).

  • Prior Art Relied Upon: Duan (Application # 2006/0185830), Admitted Prior Art ("APA") from the ’196 patent specification.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that where Duan lacked an explicit mounting mechanism, the APA from the ’196 patent’s own background section provided it. Specifically, the APA (FIG. 1 of the ’196 patent) discloses a frame with four holes designed to fasten a cooling apparatus to a motherboard, satisfying the "clip having legs" limitation of claim 5 and the "set of four mounting legs" of claim 10. The APA also explicitly shows a fan used with a heat sink, teaching the limitation of claim 8.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the known mounting and fan configurations shown in the APA with Duan's cooling module. Since Duan's module must be secured to a CPU to function, using a standard mounting frame as shown in the APA would be an obvious and necessary implementation step. Likewise, adding a fan from the APA to Duan's radiator is a known method to improve cooling efficiency.
    • Expectation of Success (for §103 grounds): The expectation of success would be high because the APA represents conventional, well-understood techniques for mounting and cooling computer components.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Duan in view of Duan-1 (Patent 7,325,591); Duan in view of the APA and further in view of Wu; and Duan in view of Duan-1 and further in view of Wu.

4. Key Claim Construction Positions

  • "reservoir": Petitioner relied on the parties' stipulated construction from a co-pending district court case: "a single receptacle defining a fluid flow path." This construction was used to argue that Duan’s integrated components collectively form the claimed reservoir.
  • "an inlet … positioned below a center of the impeller": Petitioner argued this phrase does not require a specific vertical orientation but should be construed as "an opening for fluid entrance near the center of the impeller along the axis around which the impeller rotates." This contextual interpretation was critical to mapping Duan’s structure, where the inlet provides liquid toward the center of the pump chamber, onto the claim language.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, asserting several factors favored institution.
  • Strong Merits: The petition relied on the same primary prior art (Duan) that the Board had previously used to institute IPRs against highly similar claims in related patents (’681 and ’355), suggesting a strong likelihood of prevailing.
  • Trial Date Uncertainty: Petitioner noted that the co-pending district court trial, though scheduled, was likely to be postponed due to court backlogs, mitigating concerns about inefficiency and overlap.
  • Stipulation: Petitioner stipulated that if the IPR were instituted, it would not pursue the same invalidity grounds in the district court action, eliminating the risk of duplicative efforts.

6. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-19 of the ’196 patent as unpatentable.