PTAB

IPR2022-00603

Google LLC v. Scramoge Technology Ltd

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Power Receiver and Method of Manufacturing the Same
  • Brief Description: The ’740 patent relates to a wireless power receiver designed to reduce its overall thickness. This is purportedly achieved by disposing a coil unit directly on a top surface of a magnetic substrate, with a connecting unit, such as a flexible printed circuit board, placed within a receiving space in the substrate.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1 and 3 by Goma

  • Prior Art Relied Upon: Goma (Japanese Patent Application Publication No. JP 2011-210937).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Goma discloses every limitation of claims 1 and 3. Goma teaches a coil module for wireless power reception that includes a resin structural body (3) containing magnetic material, which Petitioner mapped to the claimed "magnetic substrate." An opening (32) in this resin body, which accommodates a circuit board, was argued to meet the "first and second receiving space" limitations under the Patent Owner's broad interpretation. Goma's coil (2) is on the resin body, and its circuit board (4) functions as the "connecting unit," with all required terminals and wiring layers disclosed and positioned as claimed. For claim 3, Goma’s circuit module (43) was identified as the claimed "receiving circuit," which is connected to the wiring layer and disposed outside the receiving spaces.

Ground 2: Claims 1-10 are obvious over Goma in view of Yamazaki

  • Prior Art Relied Upon: Goma and Yamazaki (Patent 7,852,184).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Goma discloses most limitations of the challenged claims. However, Goma's design uses the same wire for the coil and its connections, causing the wire to overlap itself and increase the module's thickness. Yamazaki addresses this exact problem by teaching the use of an "extremely thin" flexible printed circuit board (FPCB) with internal wiring patterns to connect to the inner and outer ends of a coil, thereby avoiding the overlapping wire and creating a slimmer profile.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Yamazaki's FPCB coil connection structure with Goma's wireless power receiver. Both Goma and Yamazaki expressly state that reducing the thickness of the coil module is a desirable objective. A POSITA seeking to make Goma's module thinner and more compact would have looked to known solutions like Yamazaki, which is directed to the same subject matter (wireless power receivers for portable devices) and has similar components.
    • Expectation of Success: A POSITA would have had a high expectation of success. Modifying Goma's receiver by substituting its coil connection method with Yamazaki's well-known FPCB solution would have been a straightforward integration of known elements to achieve a predictable result—a thinner coil module. The petition noted that this technique was well-known in the art for reducing coil thickness.

Ground 3: Anticipation of Claims 1-6 and 8-10 by Kato

  • Prior Art Relied Upon: Kato (Application # 2008/0164840).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Kato, which discloses a noncontact power transmission coil, anticipates the claims. Kato's magnetic layer (100) was mapped to the "magnetic substrate." Under the Patent Owner’s broad interpretation, the areas in Kato's magnetic layer where electrical connections are made to the coil (and where magnetic material is absent) constitute the "first and second receiving spaces." Kato explicitly teaches a coil (40) disposed on a flexible printed-circuit board (90), which serves as the "connecting unit," and discloses all the connection terminals and wiring layers required by the claims. For claims 6 and 8, Kato's adhesion sheet (42) was argued to be the claimed "adhesive layer."

  • Additional Grounds: Petitioner asserted an additional anticipation challenge (Ground 4) alleging that claims 6-8 are anticipated by Okada (Application # 2009/0284341).

4. Key Claim Construction Positions

  • "receiving space" (claims 1 and 6): Petitioner did not propose a specific construction. Instead, it relied on the Patent Owner's broad interpretation from co-pending district court litigation, where the Patent Owner argued the term is simply a "space" that is "meant to 'receive' the 'connecting unit' in some fashion." Petitioner argued that under this broad reading, any space, recess, or opening in a substrate or adhesive where a connection is made constitutes a "receiving space," which is central to its anticipation arguments.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise discretionary denial under the Fintiv factors. The co-pending district court case was in its early stages, with fact discovery ongoing but no depositions taken or claim construction completed. Petitioner contended that the trial date, set approximately six months before the projected Final Written Decision (FWD), was uncertain due to a pending motion to transfer venue. Further, Petitioner argued that an IPR would be more efficient as it challenges all asserted claims, whereas the district court rules require the Patent Owner to narrow the number of asserted claims before trial.
  • Petitioner also argued against denial under General Plastics, stating this is its first petition against the ’740 patent. While a related IPR was filed by Apple (IPR2022-00118), it challenges a different set of claims (6, 7, 16, 17, 19, 20) than those uniquely challenged in this petition (1-5, 8-10), and uses different prior art.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10 of the ’740 patent as unpatentable.