Apple Inc v. Scramoge Technology Ltd

1. Case Identification

• Case #: IPR2022-00573
• Patent #: 7,825,537
• Filed: February 10, 2022
• Petitioner(s): Apple Inc.
• Patent Owner(s): Scramoge Technology Ltd.
• Challenged Claims: 1-22 and 28

2. Patent Overview

• Title: Inductive Power Transfer Systems
• Brief Description: The ’537 patent discloses systems for inductive wireless power transfer. The purported invention involves monitoring a parameter indicative of power transfer efficiency and automatically adjusting a characteristic of the time-varying electric current in the base unit, such as its operating frequency, to maximize that efficiency by inducing a self-resonant oscillation in the target unit.

3. Grounds for Unpatentability

Ground 1: 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) and Partovi-002 (Application # 2007/0279002).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Baarman taught the core elements of the challenged claims, including an inductive power transfer system that maximizes efficiency by adjusting operating frequency. Baarman’s system monitors parameters (e.g., primary and secondary voltage/current) to calculate power transfer efficiency and dynamically adjusts the frequency to maintain the system at resonance. Petitioner asserted that Partovi-002 supplied the limitation of positioning the target unit’s inductive element within a predetermined distance of the base unit's element, as Partovi-002 explicitly disclosed using magnets or mechanical structures (e.g., a cup-shaped base) for automatic and reliable alignment.
  • Motivation to Combine: A POSITA would combine Partovi-002’s well-understood alignment structures with Baarman’s adaptive power supply to achieve predictable benefits. These benefits, explicitly taught in Partovi-002, included enhanced magnetic coupling, improved power transfer efficiency, and greater user convenience by reducing alignment errors.
  • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying a known alignment solution to a known type of wireless power system to achieve the well-known benefits of proper coil alignment.

Ground 2: 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 described an inductive charging apparatus with a charger (base unit) and a secondary unit (target unit). It taught positioning the secondary unit on a "dished" charging surface to ensure alignment within a predetermined distance. Critically, Flowerdew taught using a "sense coil" to provide a feedback signal to a microcontroller, which then automatically adjusted the drive frequency to "maintain resonance" and achieve "high efficiency," directly corresponding to the ’537 patent's central concept of monitoring a parameter to maximize efficiency.

Ground 3: 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) and Jang (Application # 2004/0218406).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed claims requiring features Petitioner argued were not expressly disclosed in Flowerdew. Specifically, Jang was cited for its teaching of producing the time-varying current by switching a DC voltage source using electronically controlled switches (claim 3) and comparing a measured parameter to a constant reference value (claim 5). Jang described a feedback loop that minimized the error between a sensed current and a constant reference signal to maintain a "constant energy transfer," which is analogous to operating at a predetermined power level in a standby mode.
  • Motivation to Combine: A POSITA would combine Jang’s teachings with Flowerdew’s system for predictable improvements. Implementing Flowerdew’s charger with Jang’s common electronically-controlled switching circuit topology was a well-known design choice. Furthermore, a POSITA would incorporate Jang’s current-stabilizing feedback loop into Flowerdew’s system to ensure stable operation in low-power or standby modes, preventing current drift and improving reliability.
  • Expectation of Success: The combination represented the application of standard power electronics design principles (from Jang) to a known inductive charging system (Flowerdew), which would have predictably resulted in a more robust and efficiently controlled device.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Baarman and Partovi-002 with Partovi-413 (for its teachings on DC-DC switching mode power supply circuits) and combining Flowerdew and Jang with Partovi-413.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under both §325(d) and the Fintiv factors.
• §325(d): Denial was argued to be unwarranted because the primary references (Baarman and Flowerdew) and all secondary references were never cited or applied by the Examiner during the original prosecution of the ’537 patent. Petitioner contended the asserted grounds were therefore materially different from those previously considered.
• Fintiv Factors: Petitioner argued the factors weighed heavily in favor of institution, as the petition was filed early in the parallel district court litigation (less than four months after the complaint was filed) and before a trial date or substantive scheduling order had been issued. Petitioner asserted this early filing minimized any potential for duplicative efforts or inefficient use of resources.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-22 and 28 of Patent 7,825,537 as unpatentable.