PTAB

IPR2022-00643

Google LLC v. Scramoge Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Power Transfer Device and Wireless Power Transfer System
  • Brief Description: The ’392 patent is directed to a wireless power transfer transmitter designed to enhance power transfer efficiency. The technology centers on a power conversion part, configured as a full bridge inverter with four switching elements, and a control part that generates specific AC power control signals to modulate the output voltage and control the duty ratio of power transfer.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, and 5-8 are Anticipated by Sadakata

  • Prior Art Relied Upon: Sadakata (Patent 9,660,514).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sadakata, which discloses a power feeding device for a non-contact charging system, teaches every limitation of the challenged claims. Sadakata’s power feeding device was equated to the claimed "transmitter." Its "control circuit 6" was argued to be the claimed "control part" that generates first to fourth AC power control signals. Sadakata’s "inverter circuit 20" was mapped to the claimed "power conversion part," which includes four switching elements (21, 23, 26, and 28) configured as a full bridge inverter. Petitioner asserted that Sadakata discloses operating these switches in synchronized pairs: turning on switches 21 and 28 generates a positive polarity output voltage, while turning on switches 23 and 26 generates a negative polarity output voltage. Furthermore, Petitioner contended that Sadakata explicitly teaches that the duty ratio (Ton) of the positive and negative output pulses is determined by the falling time of the corresponding AC power control signals, directly mapping to the limitations of claim 1. For dependent claims, Petitioner argued Sadakata’s control circuit adjusts power output based on feedback from the receiver, meeting claim 2, and shows that maximum power is achieved at a 50% duty factor, anticipating claim 5.

Ground 2: Claims 1, 2, and 5-8 are Obvious over Sadakata

  • Prior Art Relied Upon: Sadakata (Patent 9,660,514).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, addressing the possibility that the Board might find Sadakata does not explicitly disclose connecting the lower-side switching elements (23 and 28) to "ground" as required by claim limitations 1[e] and 1[g]. Petitioner asserted that Sadakata’s disclosure of a DC power source for the inverter, derived from a full-wave rectifier, implies a ground reference.
    • Motivation to Combine (for §103 grounds): Petitioner argued a person of ordinary skill in the art (POSITA) would have found it obvious to use ground as the common voltage reference for the DC power supplied to the inverter. This represents a simple, conventional, and predictable design choice that avoids the need for additional, more complex biasing circuitry.
    • Expectation of Success: A POSITA would have had a high expectation of success, as using a ground reference for a DC power supply in such circuits is a fundamental and routine implementation technique.

Ground 3: Claims 1, 2, and 5-8 are Obvious over Sadakata in view of Schulman

  • Prior Art Relied Upon: Sadakata (Patent 9,660,514) and Schulman (Patent 3,942,535).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground reinforces the argument from Ground 2. Petitioner argued that to the extent Sadakata is viewed as not disclosing the claimed ground connections, Schulman explicitly remedies this. Schulman, a 1976 patent concerning wireless power transfer, expressly discloses a full-wave rectifying network that is referenced to ground and used to convert an AC signal to a DC signal. Sadakata teaches the core inverter architecture, while Schulman provides the explicit teaching for a ground-referenced DC power source.
    • Motivation to Combine (for §103 grounds): A POSITA implementing Sadakata's circuit would be motivated to look to other references in the wireless power field, such as Schulman, for well-known implementation details for components like the rectifier. A POSITA would combine Schulman's conventional ground-referenced rectifier with Sadakata's inverter to achieve a fully functional and predictably operating system, using a standard and reliable design.
    • Expectation of Success: A POSITA would have a high expectation of success in implementing the rectifier of Sadakata with a ground reference as taught by Schulman, as this constitutes the combination of known elements for their intended purposes in a predictable manner.

4. Arguments Regarding Discretionary Denial

  • Discretionary Denial under Fintiv: Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigations are in their infancy. Key factors cited were that no trial dates have been set, discovery has not commenced, and no substantive court orders have been issued. Petitioner also noted that the IPR challenges claims not asserted in the district court, promoting systemic efficiency, and that the petition has exceptionally strong merits.
  • Discretionary Denial under General Plastic: Petitioner contended this is not an improper serial petition. It is the first IPR filed by Google and Samsung against the ’392 patent. Petitioner argued it is not related to other petitions filed by different parties (Apple, AnkerDirect), presents different grounds (anticipation), and was filed before any institution decision in the other IPRs, meaning Petitioner could not have engaged in improper gamesmanship.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, and 5-8 of the ’392 patent as unpatentable.