PTAB

IPR2022-01053

Samsung Electronics Co Ltd v. Scramoge Technology Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Power Transmission Coil
  • Brief Description: The ’269 patent relates to coils for wireless power transmission, specifically litz coils comprising a plurality of insulated wires. The technology aims to prevent sparks caused by potential differences between wires by shorting the wires together with conductors at predetermined intervals.

3. Grounds for Unpatentability

Ground 1: Anticipation over Tamata - Claims 1, 4-8, and 10 are anticipated by Tamata.

  • Prior Art Relied Upon: Tamata (Patent 7,295,096).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tamata, which discloses a multi-layer inductor for use in a resonant circuit, teaches every limitation of the challenged claims. Tamata’s inductor comprises multiple stacked spiral metal wires (a "plurality of wires") formed on respective insulating layers ("insulated from each other"). Petitioner contended that the conductive via holes in Tamata, which connect adjacent metal wires through the insulating layers at regular intervals, constitute the claimed "shorts" at "predetermined intervals." Tamata also disclosed connecting its inductor to a capacitor to form a resonant circuit, satisfying the capacitor limitation. The dependent claims were also allegedly disclosed, with the insulating layer (claim 4), the conductive via holes (claims 5, 6, 8), the holes in the insulator for the vias (claim 7), and the spiral wire pattern (claim 10) all expressly shown in Tamata's figures and description.

Ground 2: Obviousness over Tamata and Partovi - Claims 1, 2, 4-8, and 10 are obvious over Tamata in view of Partovi.

  • Prior Art Relied Upon: Tamata (Patent 7,295,096) and Partovi (Application # 2009/0096413).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that to the extent the preamble of claim 1 ("A coil for wirelessly transmitting or receiving power") is limiting and not taught by Tamata, Partovi supplied this teaching. Partovi explicitly disclosed using multi-layer inductors, structurally and functionally similar to Tamata's, for efficient wireless power transfer in portable devices. The remaining limitations of claims 1 and 4-10 were met by Tamata as detailed in Ground 1. For claim 2, Petitioner argued that selecting a shorting interval within the broad range of 0.01 m to 100 m was an obvious design choice for a POSITA implementing Tamata's coil.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Tamata's low-resistance, multi-layer inductor structure with Partovi’s wireless charging system to achieve the benefits described by Partovi, namely more efficient power transfer through high flux density and low resistance. Partovi taught that low-resistance coils were desirable, and Tamata provided a method for creating such a coil.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success because both references described similar stacked-coil inductor technology, and Partovi provided clear teachings on how to implement such inductors in a wireless power transfer system.

Ground 3: Obviousness over Wotherspoon and Cook - Claims 1, 2, 4-8, and 10 are obvious over Wotherspoon in view of Cook.

  • Prior Art Relied Upon: Wotherspoon (Application # 2007/0126544) and Cook (Application # 2009/0015075).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Wotherspoon disclosed an inductor ("coil unit") with two square turns ("plurality of wires") separated by an insulating layer. The turns were shorted together not only at their ends but also at an intermediate point, satisfying the "shorted at predetermined intervals" limitation. To the extent Wotherspoon did not explicitly teach using this inductor for wireless power transfer, Cook disclosed using similar inductive loops and high-Q resonant antennas (coil and capacitor) for that exact purpose. For claim 2, Wotherspoon's disclosure of a 10 mm x 10 mm substrate resulted in a coil circumference of approximately 40 mm (0.04 m), which fell within the claimed range for the shorting interval.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Wotherspoon's inductor with Cook's system to improve performance. Cook recognized the desirability of high quality factor (Q) coils for efficient power transfer, and Wotherspoon taught a specific inductor design with shorting connections explicitly to provide an "inductive component of improved Q."
    • Expectation of Success (for §103 grounds): Success was predictable because the combination involved implementing a known type of high-performance component (Wotherspoon's inductor) into a well-understood system (Cook's wireless power transmitter) to achieve a predictable improvement in efficiency.

  • Additional Grounds: Petitioner asserted that claim 2 is obvious over Tamata alone as the claimed interval range is a result-effective variable. Petitioner also asserted an additional obviousness challenge against claims 1, 2, 4-8, and 10 based on Kita (Patent 7,403,090) in view of Partovi.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under the Fintiv factors would be inappropriate. The parallel district court case was in its infancy, with minimal investment by the parties and no significant rulings issued. Petitioner asserted it was diligent in filing the IPR petition shortly after receiving infringement contentions. Furthermore, Petitioner argued there was no overlap between the petition's grounds and any invalidity contentions in the district court case, as none had been served. Finally, Petitioner highlighted the strong public interest in reviewing and canceling claims of a potentially invalid patent.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1, 2, 4-8, and 10 of Patent 9,601,269 as unpatentable.