PTAB

IPR2022-00241

Samsung Electronics Co Ltd v. Scramoge Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electromagnetic Booster for Wireless Charging and Method of Manufacturing the Same
  • Brief Description: The ’482 patent discloses an electromagnetic member for wireless charging systems. The technology centers on a configuration using a first magnetic sheet member and a second magnetic sheet member disposed on the same plane, where the second sheet is positioned at an inner side of the first, and both include coil members and have different magnetic permeability rates.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-4, 6-7, 10, 11, 13, and 14 over [Kim](https://ai-lab.exparte.com/case/ptab/IPR2022-00241/doc/1005) in view of [Mizutani](https://ai-lab.exparte.com/case/ptab/IPR2022-00241/doc/1007)

  • Prior Art Relied Upon: Kim (Korean Application # 10-1163574) and Mizutani (Japanese Patent # 4924122).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim discloses the core structural arrangement of the independent claims: an electromagnetic absorber for wireless charging with a first magnetic sheet ("first absorbing sheet 110") and a second magnetic sheet ("second absorbing sheet 120") each including a coil ("antenna pattern"). Kim’s figures show the second sheet is positioned inside the first, and both are placed on the same plane. To the extent Kim does not explicitly teach that the sheets must have different magnetic permeability rates, Petitioner asserted Mizutani supplies this limitation. Mizutani teaches a non-contact transmission device with a "power core" and a "data core" made of materials with different magnetic permeabilities to suppress interference and reduce signal transmission errors.
    • Motivation to Combine: Petitioner contended that both Kim and Mizutani address the well-known problem of reducing interference between power and communication coils in wireless charging devices. A person of ordinary skill in the art (POSITA), seeking to improve the performance of Kim's device, would have looked to known solutions like Mizutani's. Petitioner argued a POSITA would combine Mizutani’s use of different permeability materials with Kim's structural layout to further reduce interference and improve communication efficiency.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a reasonable expectation of success because the combination involves applying a known interference-reduction technique (different permeabilities) from Mizutani to a conventional wireless charging structure (Kim's concentric sheets). Both references use well-understood components in predictable ways.

Ground 2: Obviousness of Claims 5, 9, 15, 16, 17, 18, 19, and 21 over Kim in view of Mizutani and [Tabata](https://ai-lab.exparte.com/case/ptab/IPR2022-00241/doc/1009)

  • Prior Art Relied Upon: Kim (Korean Application # 10-1163574), Mizutani (Japanese Patent # 4924122), and Tabata (Japanese Publication # 5013019).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the Kim and Mizutani combination to address limitations in dependent claims and independent claim 16. Petitioner argued that Tabata, another reference in the field of non-contact charging, teaches the remaining key limitations. Specifically, Tabata discloses using magnetic sheets with different thicknesses to improve power transmission and communication efficiency (for claims 9, 15, and 16[e]). Tabata also teaches specific coil thickness ranges (15 µm to 35 µm) that fall within the claimed range of 5 µm to 1 mm (for claims 5 and 18). Furthermore, Petitioner asserted that Kim's "protective sheet 130" teaches the "base film" limitation of claim 16, as it is a substrate laminated to the bottom of the magnetic sheets.
    • Motivation to Combine: Petitioner argued a POSITA would combine Tabata's teachings with the Kim/Mizutani system for predictable benefits. A POSITA would have been motivated to implement Tabata’s technique of varying magnetic sheet thickness to improve the charging and communication efficiency of the combined Kim/Mizutani device. Similarly, incorporating Tabata's thin NFC coil design would be an obvious way to achieve the slimmer mobile device profile that Kim explicitly identifies as a goal.
    • Expectation of Success: Petitioner claimed success would be expected, as modifying the thickness of magnetic sheets and coils as taught by Tabata are routine design optimizations in the wireless charging field. The components disclosed in all three references are similar and their integration would be straightforward for a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1, 8, 11, and 12 are obvious over Mizutani alone, and that claims 16 and 20 are obvious over Mizutani in view of Tabata.

4. Arguments Regarding Discretionary Denial

  • Petitioner presented extensive arguments that discretionary denial under §325(d) or the Fintiv factors would be inappropriate. Petitioner argued against §325(d) denial because the primary references, Kim and Mizutani, were never before the examiner. Although Tabata was cited in an Information Disclosure Statement, the examiner never discussed or applied it in a rejection, rendering the asserted grounds new and non-cumulative.
  • Regarding Fintiv, Petitioner argued that the parallel district court litigation is at a very early stage, with minimal investment by the parties or the court, as discovery and claim construction had not yet begun. Petitioner also noted that no stay had been sought or granted. Crucially, Petitioner stipulated that it would not pursue in the district court any obviousness ground that includes the primary references from the petition, which it argued weighs strongly against denial by minimizing overlap.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of Patent 9,825,482 as unpatentable under 35 U.S.C. §103.