Apple Inc v. Scramoge Technology Ltd

1. Case Identification

• Case #: IPR2022-00529
• Patent #: 10,193,392
• Filed: February 2, 2022
• Petitioner(s): Apple Inc.
• Patent Owner(s): Scramoge Technology Ltd.
• Challenged Claims: 1-8

2. Patent Overview

• Title: Wireless Power Transmitter with Full-Bridge Inverter
• Brief Description: The ’392 patent discloses a wireless power transfer system featuring a transmitter with a full-bridge inverter. The inverter uses four switching elements controlled by specific AC power control signals to convert a DC voltage into an AC voltage for wireless power transmission.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hui (Phase-Shift Embodiment) - Claims 1 and 6 are obvious over Hui.

• Prior Art Relied Upon: Hui (Application # 2011/0199045).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Hui’s phase-shift control embodiment (Figs. 1a, 5b) discloses every limitation of claims 1 and 6. Hui teaches a wireless power transfer device with a DC-AC power converter (inverter) having a four-transistor, full-bridge topology identical to that claimed in the ’392 patent. Petitioner asserted that Hui’s control signals (Gate1-Gate4) and resulting output voltage waveform (Vab) explicitly show how pairs of switching elements are turned on to generate positive and negative polarity output voltages. Furthermore, the petition mapped how the falling times of specific control signals in Hui’s Fig. 5b directly determine the duty ratio of the positive and negative portions of the output voltage, as required by claim 1. For claim 6, Petitioner argued Hui's waveforms clearly illustrate time intervals where one pair of switches (e.g., first and fourth) is on while the other pair (second and third) is off.

Ground 2: Obviousness over Hui in view of Taylor - Claims 2-4 are obvious over Hui and Taylor.

• Prior Art Relied Upon: Hui (Application # 2011/0199045) and Taylor (Patent 10,250,083).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on the teachings of Hui’s phase-shift embodiment for the base system. Petitioner contended that Taylor supplies the limitation of claim 2: regulating the duty ratio based on the receiver's power status. Taylor teaches adaptive control systems for wireless power supplies that adjust operating parameters, specifically including duty cycle, based on feedback from the remote device to maximize efficiency. This feedback, which includes information on the amount of power being received, constitutes a "power receiving status." Petitioner argued that claims 3 and 4, which relate to the relative timing of the control signals' falling edges, are independently taught by the waveforms shown in Hui’s Fig. 5b.
  • Motivation to Combine: A POSITA would combine Hui with Taylor to improve Hui’s system with a well-known, standardized technique. Hui’s stated goal is to achieve optimal power transfer efficiency but it lacks the specific implementation details for adaptive control. Taylor provides these exact details, describing conventional feedback methods (part of the Qi standard) for maximizing efficiency. The motivation was to apply Taylor's known optimization technique to Hui's similar wireless power system to achieve the predictable result of improved efficiency and broader market compatibility.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because both references address wireless power transfer technology, and Taylor describes a standardized, conventional solution to the exact problem of optimizing power transfer that Hui seeks to solve.

Ground 3: Obviousness over Hui (Duty-Cycle Embodiment) - Claims 1, 5, 7, and 8 are obvious over Hui.

• Prior Art Relied Upon: Hui (Application # 2011/0199045).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that an alternative embodiment in Hui, which uses duty-cycle control (Figs. 1b, 2a), also renders the claims obvious. This embodiment again discloses the full-bridge inverter structure of claim 1. For claim 5, Hui explicitly states that its output voltage magnitude is controlled by "varying the duty cycle from 0 to 0.5" and that the "output voltage increases with increasing duty cycle." Petitioner asserted this directly teaches that maximum AC power is generated at a 50% duty ratio and that the power magnitude is reduced when the duty ratio is decreased. For claims 7 and 8, Petitioner contended that the waveforms in Hui’s Fig. 2a illustrate the claimed "first blank interval" and "second blank interval," where specific pairs of control signals are not simultaneously high between their respective rising and falling edges.

4. Arguments Regarding Discretionary Denial

• Fintiv Factors: Petitioner argued that discretionary denial under Fintiv would be inappropriate. It asserted that the parallel district court litigation was in a very early stage, with no trial date set, minimal investment by the parties, and no substantive overlap on invalidity issues, as preliminary invalidity contentions had not been served. Petitioner also highlighted its prompt filing of the IPR petition within one week of receiving the Patent Owner's infringement contentions.
• §325(d) (Same or Substantially the Same Art): Petitioner contended that denial under §325(d) was not warranted because the Examiner did not consider Hui or Taylor during the original prosecution of the ’392 patent. The petition argued the challenges were non-cumulative because the cited art teaches the specific limitations—particularly the determination of duty ratio by the falling times of control signals—that the Examiner found lacking in the art of record during prosecution.
• General Plastic Factors: Petitioner noted that these factors were not applicable because the ’392 patent had not been the subject of any previous IPR petitions.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-8 of Patent 10,193,392 as unpatentable under 35 U.S.C. §103.