Samsung Electronics Co Ltd v. Scramoge Technology Ltd

1. Case Identification

• Case #: IPR2022-00653
• Patent #: 10,199,876
• Filed: February 28, 2022
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Scramoge Technology Ltd.
• Challenged Claims: 1-3, 5-7

2. Patent Overview

• Title: Wireless Power Transmitter
• Brief Description: The ’876 patent discloses a wireless power transmitter designed to mitigate heat generated by the transmission coil during operation. The invention is directed to a system of air circulation using an inlet device and a series of passage grooves to cool the coil and prevent component degradation.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness of Claims 1, 5-7 over Sasaki

• Prior Art Relied Upon: Sasaki (Japanese Patent Publication No. JP2011-135729)
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Sasaki discloses every limitation of claims 1 and 5-7. Sasaki teaches a non-contact power transmitting device for vehicles that addresses the same heat-generation problem as the ’876 patent. Specifically, Petitioner mapped Sasaki’s "cooling device 250," which includes a "blower 251" and "supply conduit 252," to the claimed "inlet device." Sasaki’s "annular cooling media path" was mapped to the "first passage groove," which surrounds the transmission coil (primary resonant coil 240). This path has an inlet port and an outlet port on opposite sides. Finally, Sasaki’s "exhaust conduit 253" was mapped to the "second passage groove," which communicates with the first passage groove to allow air to flow outside. For dependent claims 5 and 6, Petitioner asserted that Sasaki's annular path inherently surrounds the coil and has a close-loop structure. For claim 7, Sasaki's inlet device explicitly includes a blower.
  • Key Aspects: The core of this ground is that Sasaki's device for cooling a wireless power transmitter in a vehicle is structurally and functionally identical to the device claimed in the ’876 patent.

Ground 2: Obviousness of Claim 2 over Sasaki in view of Kajiura

• Prior Art Relied Upon: Sasaki (Japanese Patent Publication No. JP2011-135729) and Kajiura (Patent 6,366,050)
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Sasaki discloses most elements of claim 2, including the base transmitter of claim 1, a "transmission coil receiving unit" (Sasaki’s bobbin 228), and a connected "power supply device" (Sasaki’s high-frequency power driver 220). The limitation missing from Sasaki is using the same air flow to cool both the transmission coil and the power supply device. Kajiura was introduced to supply this missing element, as it explicitly teaches using a fan and cooling duct to cool the power supply circuit board of a wireless power transmitter. Petitioner argued it would have been obvious to apply Kajiura's teaching to Sasaki's system.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Sasaki and Kajiura because both address the same technical problem—cooling components in wireless power transmitters for vehicles. A POSITA would have recognized the benefit of using a single fan or blower to provide airflow for removing heat from both the transmission coil (as taught by Sasaki) and the power supply (as taught by Kajiura), thereby reducing component count, cost, and complexity.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as it involved applying a known cooling technique (cooling a power supply) to a similar system that already used air cooling for another component (the transmission coil).

Ground 3: Obviousness of Claim 3 over Sasaki, Yamakawa, and Kim

• Prior Art Relied Upon: Sasaki (JP2011-135729), Yamakawa (Japanese Patent Publication No. JP2011-216569), and Kim (Patent 9,350,193)

• Core Argument for this Ground:

  • Prior Art Mapping: This ground builds on the combination of Sasaki and Yamakawa to establish the foundation of claim 2, with Yamakawa providing an alternative teaching for cooling both the transmission coil and power supply with the same airflow. The challenge to claim 3 focuses on the specific internal components of the "power supply device." Petitioner argued that while Sasaki discloses a high-level "high frequency power driver," it does not detail its internal components. Kim was introduced because it discloses a wireless power transmitter with the specific power supply components recited in claim 3, including a power supply unit, a DC-DC converter, a current sensing unit, an oscillator, an AC power generating unit, and a control unit.
  • Motivation to Combine: A POSITA, seeking to implement the functional block of Sasaki’s power driver, would have been motivated to consult prior art like Kim for well-known, conventional power converter circuit designs. The combination amounts to implementing a functional block diagram (Sasaki) with known, off-the-shelf circuit components and arrangements (Kim).
  • Expectation of Success: Success would be expected because the combination merely integrates a standard power supply architecture, as detailed in Kim, into the broader system of Sasaki. The components described in Kim were well-known and their integration would have been a matter of routine engineering.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including Claim 2 over Sasaki and Yamakawa, and Claim 3 over Sasaki, Kajiura, and Kim. These grounds relied on similar arguments, substituting Yamakawa for Kajiura as the reference for cooling a power supply, or vice versa.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) based on Fintiv factors. The parallel district court litigation was in its early stages, with no trial date set, minimal investment by the parties, and fact discovery not yet open. Petitioner further noted that it had filed its petition promptly after receiving infringement contentions. Crucially, Petitioner stipulated that it would not pursue in the district court any invalidity grounds based on anticipation by Sasaki or any obviousness ground that includes Sasaki as the primary reference, thereby streamlining issues and mitigating concerns of duplicative efforts.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-3 and 5-7 of the ’876 patent as unpatentable.