PTAB

IPR2022-00284

Samsung Electronics Co Ltd v. Scramoge Technology Ltd

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Receiving Antenna for Wireless Charging
  • Brief Description: The ’962 patent is directed to a wireless charging receiving antenna comprising a substrate, a soft magnetic layer, a receiving coil disposed on the magnetic layer, and an adhesive layer. The invention focuses on the structural arrangement of these layers, including claims where the receiving coil is embedded within the magnetic layer.

3. Grounds for Unpatentability

Ground 1: Claims 1-8 and 18-19 are obvious over Suzuki in view of Okada.

  • Prior Art Relied Upon: Suzuki (Patent 9,515,513) and Okada (Application # 2009/0284341).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Suzuki taught a combo coil module for a mobile device with a wireless power receiving coil and an NFC coil arranged on a single magnetic sheet, which is mounted on a battery pack (the claimed "substrate"). While Suzuki disclosed the basic antenna structure, it did not explicitly teach a soft magnetic layer composed of two stacked magnetic sheets. Okada was argued to supply this limitation by disclosing a coil unit for contactless power transmission that uses a multilayer magnetic body with a plurality of layered magnetic substances. This multi-layer structure was taught by Okada to provide desired coil characteristics and reduce magnetic flux leakage.
    • Motivation to Combine: A POSITA would combine Suzuki and Okada to improve the performance of Suzuki's antenna. Petitioner asserted a POSITA would recognize the benefit of implementing Suzuki’s single magnetic sheet as a multilayer body, as taught by Okada, to achieve the known advantages of improved power transfer efficiency and reduced flux leakage.
    • Expectation of Success: Both references operate in the same field of wireless charging, address similar problems with predictable technologies, and use well-known components, making their combination straightforward with a reasonable expectation of success.

Ground 2: Claims 1-8 and 18-19 are obvious over Suzuki in view of Lee.

  • Prior Art Relied Upon: Suzuki (Patent 9,515,513) and Lee (Patent 9,252,611).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative combination to arrive at the challenged claims. As in Ground 1, Suzuki provided the foundational dual-mode antenna structure. Lee was argued to teach the use of a multi-layered magnetic sheet to support both NFC and wireless charging functions. Specifically, Lee disclosed a "hybrid-type thin film magnetic sheet" created by laminating an amorphous ribbon sheet and a ferrite sheet. This hybrid sheet was disclosed as beneficial for supporting the dual functions of a dual-mode antenna. Lee also taught affixing coils using double-sided tape with a PET insulating layer, mapping to limitations regarding the adhesive layer structure.
    • Motivation to Combine: A POSITA would combine the teachings of Suzuki and Lee to enhance the performance of Suzuki’s dual-mode antenna. Petitioner argued that replacing Suzuki's single magnetic sheet with Lee's hybrid multi-layer sheet would better support the dual functions of NFC communication and wireless power transfer, a known objective in the art.
    • Expectation of Success: The combination was asserted to be predictable, as both references address similar problems in dual-mode antennas using routine and well-understood wireless charging technologies.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Suzuki, Okada, and Yang (Patent 8,268,092) to explicitly teach an Fe-Si based alloy for the magnetic layer (Claim 2), and combining Suzuki, Okada, and Lin (Application # 2014/0147625) to explicitly teach PET and polyimide insulating layers for the adhesive tape (Claims 5 and 6).

4. Key Claim Construction Positions

  • Petitioner argued that no terms required explicit construction but proposed a contingent construction for "support means" as recited in dependent claim 3.
  • Should the Board find the term governed by 35 U.S.C. §112(6), Petitioner proposed the following:
    • Function: "to support the receiving coil."
    • Corresponding Structure: "a film-like layer, such as a polyethylene terephthalate (PET) layer."

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under §325(d), the Fintiv factors, or the General Plastics factors.
  • §325(d): The petition relied on art and arguments not previously before the examiner. Specifically, the primary reference (Suzuki) and a key secondary reference (Okada) were not considered during prosecution.
  • Fintiv: The parallel district court litigations were argued to be in their early stages, with minimal investment in discovery and no imminent trial date that would precede a Final Written Decision (FWD). Petitioner also noted that some challenged claims were not asserted in the district court litigation.
  • General Plastics: Petitioner asserted this was its first IPR petition challenging the ’962 patent and thus should not be considered a "serial petition."

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8 and 18-19 of the ’962 patent as unpatentable under 35 U.S.C. §103.