Apple Inc v. Scramoge Technology Ltd

1. Case Identification

• Case #: IPR2022-00532
• Patent #: 9,490,652
• Filed: February 3, 2022
• Petitioner(s): Apple Inc.
• Patent Owner(s): Scramoge Technology Ltd.
• Challenged Claims: 1-5 and 7

2. Patent Overview

• Title: Wireless Charger with Auxiliary Power Supply
• Brief Description: The ’652 patent discloses a wireless charger for portable electronic devices. The charger includes a power input unit for an external power source, a wireless power transmission unit, and an auxiliary power unit with an internal battery, allowing it to operate when disconnected from the external source. Key components include a charge/discharge module to manage power flow and a boost converter to increase the battery's output voltage for wireless transmission.

3. Grounds for Unpatentability

Ground 1: Claims 1-5 and 7 are obvious over Zhu

• Prior Art Relied Upon: Zhu (Canadian Patent Application CA 2794703).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Zhu, which discloses a "portable battery charger with inductive charging," teaches every limitation of the challenged claims. Independent claim 1 recites a wireless charger with a power input unit, a wireless transmission unit, and an auxiliary power unit. Petitioner asserted that Zhu's portable charger is a "wireless charger," its AC input is a "power input unit," and its output inductive coil and transmitter form a "wireless power transmission unit." Crucially, Petitioner argued that Zhu's internal battery, "charge control switch," and "DC/DC converter" directly correspond to the claimed auxiliary power unit comprising a battery, a "charge/discharge module," and a "boost converter," which were the features relied upon for allowance during prosecution.
  • For independent claim 3, which adds a first and second power input unit, Petitioner mapped Zhu’s "AC input 52" as the first unit and its "input inductive coil 53" as the second. Petitioner contended Zhu explicitly teaches powering its wireless transmission unit from either of these inputs.
  • For dependent claims, Petitioner argued Zhu’s "output connector 65" (e.g., a USB port) configured in parallel with its inductive coil teaches the "wired output unit" of claims 2 and 5. Petitioner also argued Zhu’s "junction 63" functions as the claimed "switch" in claim 7, as it controls the electrical connection between the AC input and the wireless transmission unit.
  • Key Aspects: Petitioner argued that even though Zhu does not explicitly state that its "inductive charging" transmits power "through a magnetic field," this was a fundamental and well-understood principle of the technology at the time. A person of ordinary skill in the art (POSITA) would have found it obvious that Zhu's inductive charging operated via an electromagnetic field.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under several frameworks.
• Fintiv Factors (§314(a)): Petitioner asserted that the factors weigh heavily against denial. The parallel district court litigation was in a very early stage, with no trial date set, no scheduling order issued, and minimal investment by the parties. Petitioner noted it filed the IPR petition expeditiously, just one week after receiving the patent owner's infringement contentions. Consequently, there was no significant overlap of issues, and the merits of the petition were strong.
• Same Art or Arguments (§325(d)): Petitioner argued that denial under §325(d) is unwarranted because the challenge is not cumulative to the prosecution history. The primary reference, Zhu, was never considered by the Examiner. Furthermore, Petitioner contended that Zhu specifically teaches the combination of a battery, charge/discharge module, and boost converter within an auxiliary power unit—the very limitations the Examiner identified as the basis for allowance over the previously cited art.
• General Plastic Factors: Petitioner noted that because the ’652 patent had not been challenged in any prior IPR petitions, the General Plastic factors concerning follow-on petitions are not applicable.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 7 of the ’652 patent as unpatentable under 35 U.S.C. §103.