PTAB

IPR2022-00939

Samsung Electronics Co Ltd v. Scramoge Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Power Receiver and Antenna
  • Brief Description: The ’476 patent discloses a wireless power receiver for mobile devices featuring a first antenna for wireless charging and a second antenna for wireless communication (e.g., NFC). The antennas are disposed on a flexible printed circuit board (FPCB) and covered by a magnetic sheet, with the claims detailing highly specific interconnect structures connecting the antennas to external contact terminals.

3. Grounds for Unpatentability

Ground 1: Claims 1-15 are obvious over Kato, Park, Chong, Hahn, and Ramadan

  • Prior Art Relied Upon: Kato (Application # 2008/0164840), Park (Patent 8,922,162), Chong (Patent 8,995,910), Hahn (WO 2008/016273), and Ramadan (Patent 7,791,440).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of references teaches every limitation of the challenged claims. Kato was asserted to disclose the foundational wireless power receiver, including a first antenna (charging coil) on an FPCB. The combination with Park allegedly rendered it obvious to add a second antenna (NFC coil) for wireless communication that surrounds the first antenna, a known configuration to save space and add functionality. The further combination with Chong was argued to teach placing a single magnetic sheet over both antennas to prevent performance degradation. To address the claimed complex interconnects, Petitioner asserted that Hahn taught routing conductive traces for an inner coil terminal on the backside of the FPCB to avoid overlapping wires on the front. Finally, Ramadan was argued to teach using specific conductive lines on the top surface of the FPCB to connect smaller peripheral connectors (near the coils) to larger contact terminals used for external connections (e.g., to the motherboard), a known technique for robust and manufacturable design. Petitioner contended this step-by-step combination of known elements arrives at the claimed invention.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to create an improved, multi-function antenna module for a mobile device. A POSITA would combine Kato and Park to integrate the growing trend of NFC capability with wireless charging. Chong would be added to solve the known problem of performance degradation from placing two antennas in close proximity. A POSITA would incorporate Hahn’s teachings as a known solution for routing internal coil connections without increasing module thickness. Ramadan would be consulted to implement a standard, reliable method for connecting the antenna module to the phone's main circuitry, which was a simple design choice.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying known techniques (e.g., multi-coil arrangements, shielding, backside traces, standard interconnects) from the same field to solve predictable problems, resulting in a predictable and functional antenna module.

Ground 2: Claims 13 and 14 are obvious over Kato, Park, Chong, Hahn, Ramadan, and Yu

  • Prior Art Relied Upon: Kato (Application # 2008/0164840), Park (Patent 8,922,162), Chong (Patent 8,995,910), Hahn (WO 2008/016273), Ramadan (Patent 7,791,440), and Yu (Korean Application # 10-2013-0000926).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination in Ground 1 to specifically address claims 13 and 14, which recite dimensional limitations of the coil patterns. Claim 13 requires the trace width of the first coil pattern (charging) to be wider than the second (communication), and claim 14 requires the spacing of the first coil pattern to be greater than the second. Petitioner argued that while these are merely obvious design choices, the additional reference, Yu, explicitly discloses these features. Yu teaches designing dual-coil antennas and discloses examples where the wireless charging coil has a wider trace width (e.g., 1.0 mm) than the NFC antenna (e.g., 0.9 mm) and a wider trace spacing (e.g., 0.3 mm vs. 0.1 mm).
    • Motivation to Combine: A POSITA, having arrived at the antenna design in Ground 1, would be motivated to optimize its performance. Petitioner argued that a POSITA would consult a reference like Yu to fine-tune electrical characteristics. Yu teaches that parameters like trace width and spacing are variables that can be manipulated to achieve desired performance. For example, a wider trace width for the charging coil reduces resistance and power loss, a clear benefit a POSITA would seek to implement.
    • Expectation of Success: Modifying trace width and spacing were well-known variables in antenna design with predictable effects on performance characteristics like inductance, resistance, and quality factor (Q). A POSITA would have a high expectation of success in applying Yu’s teachings to the base combination to achieve improved performance.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued the Board should not exercise discretionary denial under Fintiv. The parallel district court case was in its early stages, with no trial date set, fact discovery ongoing, and expert discovery not yet started. Petitioner noted it had filed a motion to transfer venue. Critically, Petitioner stipulated that if the IPR is instituted, it will not pursue in district court any obviousness grounds that include the primary references from the petition, thus eliminating overlap between the forums. Petitioner asserted these factors, combined with the strong merits of the petition, weigh heavily against denial.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-15 of the ’476 patent as unpatentable.