Luxshare Precision Industry Co Ltd v. Amphenol Corp

1. Case Identification

• Case #: IPR2022-00132
• Patent #: 10,381,767
• Filed: November 4, 2021
• Petitioner(s): Luxshare Precision Industry Co., Ltd.; Dongguan Luxshare Precision Industry Co., Ltd.; Luxshare Precision Limited (HK); Luxshare-ICT Inc.
• Patent Owner(s): Amphenol Corp.
• Challenged Claims: 1-32

2. Patent Overview

• Title: High Performance Cable Connector
• Brief Description: The ’767 patent relates to a board-mounted, high-performance electrical connector for small form factor pluggable (SFP) and quad small form factor pluggable (QSFP) applications. The invention purports to improve electrical performance, such as reducing crosstalk, through specific design features of its receptacle housing and internal lead assemblies.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cai - Claims 1-10 and 28-32 are obvious over Cai

• Prior Art Relied Upon: Cai (CN Utility Model Patent # 201112782).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Cai, which discloses an electrical connector with stacked insertion holes and multiple layers of conductive terminals, renders the challenged claims obvious. Petitioner mapped Cai's "insulating body" with "inserting holes" to the claimed "housing" with a "cavity." The multiple layers of "conductive terminals" in Cai were alleged to meet the limitations of a first and second plurality of conductive elements. Petitioner further contended that Cai’s "insulating blocks" correspond to the claimed "monolithic housing members." A central argument was that since the ’767 patent relies on its figures to support the "monolithic" limitation, Cai, which depicts a visually monolithic structure, should be held to the same standard.
  • Motivation to Combine (for §103 grounds): Not applicable as this ground is based on a single reference. Petitioner argued Cai’s teachings alone were sufficient, or that any minor modifications would have been obvious design choices to a POSITA.
  • Key Aspects: Petitioner repeatedly argued that because the ’767 patent specification lacks express disclosure for many precise geometrical limitations, relying instead on its figures, the prior art (Cai) must be interpreted under the same, less stringent standard.

Ground 2: Obviousness over Cai in view of Cohen - Claims 10-27 are obvious over Cai in view of Cohen

• Prior Art Relied Upon: Cai (CN Utility Model Patent # 201112782) and Cohen (Patent 7,494,383).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground asserted that a POSITA would modify the connector of Cai using teachings from Cohen to arrive at the claimed invention. Cohen taught using a "lossy insert" with projections placed between or adjacent to ground conductors specifically to reduce crosstalk in high-speed electrical connectors. Petitioner argued that incorporating Cohen's lossy insert between the lead assemblies of Cai’s connector would satisfy the limitations of claims 10-23 and 27, which recite features like an insert made of electrically lossy material (claim 11) with projections contacting selected conductors (claims 12-13).
  • Motivation to Combine: A POSITA would combine Cai and Cohen to solve the well-known problem of crosstalk. Both references address this issue. Cohen provided an explicit solution (a lossy insert) that was known to improve electrical performance, making its application to a standard connector like Cai a predictable and logical step for improving its design.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success. The combination involved applying a known crosstalk-reduction technique from Cohen to the analogous art of Cai's electrical connector. The outcome—reduced crosstalk—was the explicit purpose of Cohen's insert and would have been predictable.

Ground 3: Obviousness over Cai in view of QSFP Standard - Claims 6, 28-31 are obvious over Cai in view of QSFP Standard

• Prior Art Relied Upon: Cai (CN Utility Model Patent # 201112782) and QSFP Standard (Specification for QSFP Transceiver, Rev. 1.0).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground focused on claims requiring a "metallic cage." Petitioner argued that even if Cai's "shielding shell" was insufficient, the QSFP Standard provides an express disclosure of a standardized cage assembly used for EMI shielding. The ’767 patent itself acknowledges QSFP connectors in its background, making the standard directly relevant. The QSFP Standard’s cage assembly, designed to house a connector and shield against EMI, was alleged to meet the claim limitations.
  • Motivation to Combine: A POSITA developing a QSFP-compatible connector like that described in the ’767 patent would have been motivated to consult the QSFP Standard. The standard's requirement of a cage for EMI shielding provides a direct reason to incorporate such a cage with the receptacle design taught by Cai.
  • Expectation of Success: Combining a standard, industry-specified cage with a compatible connector receptacle was presented as a routine design choice with a high likelihood of success.

• Additional Grounds: Petitioner asserted further obviousness challenges, including that claims 9 and 28-31 are obvious over Cai in view of Droesbeke (Application # 2002/0192988) for its express disclosure of four discrete housing members, and that claims 28-31 are obvious over the combination of Cai, QSFP Standard, and Droesbeke.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be improper. Under §325(d), Petitioner contended that the primary reference, Cai, was never before the examiner, and Cohen was only cited in an information disclosure statement without substantive analysis, meaning the core grounds were not previously considered.
• Petitioner also argued against discretionary denial under Fintiv, highlighting that the co-pending district court case is stayed and the parallel ITC investigation involves a different and narrower set of asserted claims. Crucially, Petitioner stipulated that if the IPR is instituted, it will not pursue any invalidity grounds in the co-pending litigations that were raised, or could have been reasonably raised, in the IPR based on the Cai reference, thereby eliminating concerns of duplicative efforts and inconsistent rulings.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-32 of the ’767 patent as unpatentable.