Fantasia Trading LLC v. Scramoge Technology Ltd

1. Case Identification

• Case #: IPR2022-00499
• Patent #: 7,825,537
• Filed: February 1, 2022
• Petitioner(s): Fantasia Trading LLC d/b/a Ankerdirect
• Patent Owner(s): Scramoge Technology Ltd.
• Challenged Claims: 1-22 and 28

2. Patent Overview

• Title: Inductive Power Transfer System and Method
• Brief Description: The ’537 patent discloses systems for inductive power transfer that adjust the operating frequency of a primary inductive element to induce a self-resonant oscillation in a secondary inductive element, thereby maximizing power transfer efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness over Baarman and Partovi-002 - Claims 1-5, 8-16, 19-22, and 28 are obvious over Baarman in view of Partovi-002.

• Prior Art Relied Upon: Baarman (Application # 2009/0174263), Partovi-002 (Application # 2007/0279002).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Baarman taught the core limitations of the challenged claims, including an inductive power transfer system that monitors power transfer efficiency and automatically adjusts operating frequency to maximize that efficiency by maintaining resonance. Baarman allegedly failed to explicitly disclose a physical structure for positioning the secondary inductive element relative to the primary. Petitioner asserted that Partovi-002 supplied this missing element by teaching various conventional positioning structures, such as magnets or mechanical shapes (e.g., a cup), to ensure proper alignment and distance between the primary and secondary coils.
  • Motivation to Combine: A POSITA would combine Baarman's system with Partovi-002's positioning structures to achieve the predictable benefits of improved magnetic coupling and more efficient power transfer. Partovi-002's structures were presented as simple, well-known solutions to ensure convenient and user-friendly alignment, reducing the likelihood of user error.
  • Expectation of Success: A POSITA would have a high expectation of success, as combining a known positioning method with a wireless power system was a straightforward implementation to enhance a known performance metric (efficiency).

Ground 2: Anticipation by Flowerdew - Claims 1-2, 8-11, and 28 are anticipated by Flowerdew.

• Prior Art Relied Upon: Flowerdew (Patent 7,211,986).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Flowerdew disclosed every element of these claims in a single reference. Flowerdew allegedly taught an inductive charging apparatus with a base unit (charger) and a target unit. The system included a controller that monitors a feedback signal from a sense coil—a parameter indicative of efficiency—and automatically adjusts the output frequency to maximize the signal, thereby maintaining resonance and achieving high efficiency. Furthermore, Flowerdew disclosed positioning the secondary unit within a predetermined distance of the primary coil using a "dished" or "concave" charging surface that guides the secondary unit into proper alignment.

Ground 3: Obviousness over Flowerdew and Jang - Claims 3-5, 12-16, and 19-22 are obvious over Flowerdew in view of Jang.

• Prior Art Relied Upon: Flowerdew (Patent 7,211,986), Jang (Application # 2004/0218406).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner used Flowerdew as the base system, arguing it taught the core method of adjusting frequency to maximize efficiency. To the extent Flowerdew did not explicitly teach producing the time-varying current by switching a DC voltage source with an electronically controlled switch element (as required by claim 3), Petitioner asserted Jang supplied this teaching. Jang described an inductive power system that used electronically controlled high-side and low-side switches (e.g., MOSFETs) to switch a DC voltage source and produce a variable-frequency current.
  • Motivation to Combine: A POSITA would combine these references because implementing Flowerdew's system using the electronically controlled switches taught by Jang was a common and predictable design choice. Jang’s use of MOSFETs represented a well-known, readily available method for creating the "digital driver" generally described by Flowerdew, and it was necessary to enable the variable-frequency switching contemplated by both references.
  • Expectation of Success: A POSITA would expect success in applying Jang's common switching circuit topology to Flowerdew's system to achieve the desired variable-frequency control, as it was a standard implementation for power electronics.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Baarman with Partovi-002 and Partovi-413 (for teaching DC-DC switching topologies), and combining Flowerdew with various combinations of Jang and Partovi-413.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. §325(d), stating that the primary references (Baarman and Flowerdew) and all secondary references were never cited or applied during the original prosecution, making the petition’s art and arguments materially different and non-cumulative.
• Petitioner also argued against discretionary denial under Fintiv, emphasizing that the petition was filed very early in the parallel district court litigation (less than four months after the complaint was filed), long before a trial schedule was set, minimizing any overlap or inefficiency.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-22 and 28 of the ’537 patent as unpatentable.