Samsung Electronics Co Ltd v. Lynk Labs Inc

1. Case Identification

• Case #: IPR2022-00149
• Patent #: 10,687,400
• Filed: November 12, 2021
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Lynk Labs, Inc.
• Challenged Claims: 7-20

2. Patent Overview

• Title: LED Lighting System and Device
• Brief Description: The ’400 patent relates to LED lighting systems that operate from an AC power source. The technology describes driving an LED circuit array with a driver and a bridge rectifier, where the components are mounted on a single substrate.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nerone and Martin - Claims 7, 9, and 11 are obvious over Nerone in view of Martin.

• Prior Art Relied Upon: Nerone (Patent 6,411,045) and Martin (Application # 2004/0206970).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Nerone discloses the core elements of independent claim 7. Nerone teaches a power supply circuit for an LED traffic signal, which constitutes a "lighting system." This system includes an LED circuit array with series-connected LEDs, capacitors, and a bridge rectifier configured to receive an input AC voltage from a mains power source. Nerone also discloses that all circuit components may be placed on a single circuit board ("substrate").
  • Motivation to Combine (for §103 grounds): Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Nerone's circuit with the teachings of Martin to ensure proper and safe operation of the LEDs. Martin addresses the known problem of LED damage from excessive forward voltage and teaches selecting the number of series-connected LEDs to match the voltage drop to the driver's output. A POSITA would apply this routine optimization to Nerone’s system to provide a stable circuit design. For dependent claims, Martin’s teachings on using phosphors to alter LED color and using capacitors to smooth voltage would be obvious additions.
  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because combining these known elements involved applying fundamental circuit design principles to achieve the predictable result of a stable, properly functioning LED lighting system.

Ground 2: Obviousness over Zhang and Martin - Claims 7, 9-11, and 17 are obvious over Zhang in view of Martin.

• Prior Art Relied Upon: Zhang (Application # 2002/0021573) and Martin (Application # 2004/0206970).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Zhang provides an alternative primary reference disclosing the limitations of claim 7. Zhang describes a "chip-on-board LED exit sign," which is a lighting system with parallel rows of series-connected LEDs, capacitors, and a bridge rectifier on a single circuit board. The system is powered from a mains commercial line via a transformer. Zhang further discloses a driver (regulator 37) connected to the bridge rectifier that provides a rectified AC voltage to the LED array.
  • Motivation to Combine (for §103 grounds): The motivation to add Martin to Zhang is the same as for the Nerone combination. A POSITA implementing Zhang’s system would be motivated by Martin's teachings to match the forward voltage of the LEDs to the driver output. This was a known technique to prevent LED damage and ensure desired brightness, representing a routine design choice. For claims 9 and 17, Petitioner argued it would have been obvious to coat Zhang’s LEDs with phosphors, as taught by Martin, to achieve a desired color.
  • Expectation of Success (for §103 grounds): Success would be expected as the combination applies a well-understood optimization technique (voltage matching) to a standard LED circuit configuration to achieve predictable operational stability.

Ground 3: Obviousness over Nerone, Martin, and Morgan - Claim 8 is obvious over Nerone, Martin, and Morgan.

• Prior Art Relied Upon: Nerone (Patent 6,411,045), Martin (Application # 2004/0206970), and Morgan (Patent 7,202,613).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground builds upon the combination of Nerone and Martin by adding Morgan to teach the "power factor correction circuitry" recited in claim 8.
  • Motivation to Combine (for §103 grounds): Petitioner argued that a POSITA would recognize that switching power supplies like the one in Nerone can have an undesirably low power factor. Morgan addresses this exact problem in the field of LED lighting, teaching the use of power factor correction (PFC) circuits to increase efficiency. A POSITA would combine Morgan's PFC solution with the Nerone/Martin system to obtain the predictable benefit of a higher power factor and improved system efficiency.
  • Expectation of Success (for §103 grounds): A POSITA would expect success because adding a PFC circuit was a known solution to a common problem in power supply design, and commercially available PFC controllers existed for this purpose.

• Additional Grounds: Petitioner asserted numerous additional obviousness challenges, including combinations based on Nerone or Zhang with other references. These included adding Zinkler for adjusting voltage levels, Michael and Gleener for integrating a wireless communication circuit, Hudson for soft-start circuitry, and Muthu for using field effect transistors in the driver.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under both 35 U.S.C. §314(a) (Fintiv) and §325(d).
• Fintiv Factors: Petitioner contended that the co-pending district court litigation was at a very early stage, with no trial date set and minimal investment by the court or parties. Petitioner stated its intent to seek a stay if the IPR is instituted and stipulated that it would not pursue any instituted IPR ground in the district court.
• §325(d) Factors: Petitioner argued that denial under §325(d) would be improper because the key prior art combinations were not previously considered by the USPTO. Although Martin was cited in an Information Disclosure Statement, it was never substantively analyzed by the examiner, and the examiner never considered it in combination with Nerone or Zhang. The ’400 patent issued after a first action allowance without the benefit of the combinations or expert testimony presented in the petition.

5. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 7-20 of Patent 10,687,400 as unpatentable.