PTAB

IPR2022-00119

Apple Inc v. Scramoge Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Power Receiving Apparatus
  • Brief Description: The ’941 patent discloses a system for wireless power transfer via electromagnetic induction. The invention centers on a wireless power receiving apparatus that includes a receiving coil and a "first magnet," and a corresponding wireless power transmitting apparatus with a "second magnet" used for alignment.

3. Grounds for Unpatentability

Ground 1: Obviousness over Baarman - Claims 1-3, 6, and 7 are obvious over Baarman.

  • Prior Art Relied Upon: Baarman (Patent 8,766,484).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Baarman, which predates the ’941 patent, discloses all elements of the challenged claims. Baarman teaches an inductive power transfer system comprising a "remote device" (the claimed receiving apparatus) and an "inductive power supply" (the transmitting apparatus). This system includes a secondary coil (receiving coil) and secondary magnet (first magnet) in the remote device, which are positioned to align with a primary coil and primary magnet (second magnet) in the power supply. Critically, Petitioner asserted that Baarman explicitly teaches and illustrates that the receiving coil is "positioned in the approximate center of the secondary coil," directly mapping to the key limitation of claim 1 that the receiving coil surrounds the first magnet.
    • Prior Art Mapping (Dependent Claims): Petitioner further contended that Baarman renders the dependent claims obvious. Baarman's figures show the receiving coil and first magnet disposed on the same plane (claim 2) and the first magnet disposed in a central region of the coil (claim 3). Baarman also discloses that the magnet can be a permanent magnet, such as a bonded rare earth or ceramic ferrite magnet (claim 6), and illustrates a "top and bottom magnetization" method where one face has a North polarity, inherently implying the opposite face has a South polarity (claim 7).
    • Key Aspects: Petitioner highlighted that the limitation added during prosecution to secure allowance of the ’941 patent—"wherein the receiving coil is disposed to surround the first magnet"—was already well-known and explicitly taught in Baarman.

Ground 2: Obviousness over Baarman in view of Hidaka - Claims 4 and 5 are obvious over Baarman in view of Hidaka.

  • Prior Art Relied Upon: Baarman (Patent 8,766,484) and Hidaka (Patent 9,306,411).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the teachings of Baarman, which discloses sizing magnets with "sufficient flux density" to hold the device in place but does not provide specific numerical values for flux density or magnet diameter. Petitioner argued that Hidaka, which addresses the same technical field of wireless charging, supplies these missing parameters. Hidaka teaches that magnets in such systems commonly have a flux density of 32G or more (disclosing a range of 750G to 1500G) and a diameter of 8 mm to 12 mm (disclosing a range of "about 10 to 20 mm"). This combination allegedly renders claim 4 (flux density of 32G or more) and claim 5 (diameter of 8 mm to 12 mm) obvious.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA), when implementing Baarman's system, would have been motivated to consult analogous art like Hidaka to determine suitable, well-known design parameters for magnet size and strength. The goal would be to ensure proper alignment and reliable operation, a shared objective of both Baarman and Hidaka. Hidaka provided known, predictable magnet characteristics that would optimize Baarman's alignment system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying Hidaka’s specific magnet parameters to Baarman’s general system, as it involved the application of known design choices to achieve a predictable result (effective magnetic alignment).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) based on the Fintiv factors would be inappropriate. The parallel district court litigation was in its early stages with no trial date set, minimal investment by the parties, and no overlap in prior art issues, as invalidity contentions had not yet been served. Petitioner also noted that it filed the IPR petition expeditiously, less than eight weeks after being served with infringement contentions.
  • Petitioner further contended that denial under §325(d) was not warranted because the challenge was not cumulative of the prosecution history. The Examiner who allowed the ’941 patent never considered Baarman or Hidaka. These references, particularly Baarman, were argued to teach the very limitation (a coil surrounding a magnet) that the applicant added via amendment to overcome the Examiner's rejections, making the new challenge highly relevant.

5. Relief Requested

  • Petitioner requests that the Board institute an inter partes review and cancel claims 1-7 of the ’941 patent as unpatentable under 35 U.S.C. §103.