PTAB

IPR2022-01057

Samsung Electronics Co Ltd v. Scramoge Technology Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Power Receiver and Method of Manufacturing the Same
  • Brief Description: The ’364 patent describes a wireless power receiver for use in mobile devices. The receiver comprises a shielding unit, a power receiving coil disposed on the shielding unit, and a short-range communication antenna, which is also disposed on the shielding unit and surrounds the receiving coil.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3 and 6 by Kim

  • Prior Art Relied Upon: Kim (Korean Application # 10-2008-0074640).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim discloses every limitation of claims 1-3 and 6. Kim describes a battery pack for mobile devices that functions as a wireless power receiver. This device includes a ferrite sheet that serves as the claimed "shielding unit." A flexible printed circuit board (FPCB) is installed on this ferrite sheet, and the FPCB contains both an "RF power receiving antenna" (the claimed "receiving coil") and an "RFID antenna" (the claimed "short-range communication antenna"). Petitioner asserted that Kim’s figures clearly show the RFID antenna wired along the perimeter of the FPCB, surrounding the spirally wired RF power receiving antenna in the central portion. The ferrite sheet is positioned to cover both antennas, thereby meeting all limitations of independent claim 1.
    • Key Aspects: Petitioner contended that Kim’s disclosure of an RFID antenna operating at 13.56 MHz inherently meets the limitation of an NFC antenna recited in claim 6, as NFC was a known RFID standard operating at that frequency.

Ground 2: Obviousness of Claims 1-3 and 6 over Kim and Leizerovich

  • Prior Art Relied Upon: Kim (Korean Application # 10-2008-0074640) and Leizerovich (Patent 7,202,825).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1. To the extent the Patent Owner argues Kim’s RFID antenna is not an NFC antenna as required by claim 6, Leizerovich was argued to cure this alleged deficiency. Leizerovich discloses implementing a loop antenna for NFC in a battery-powered mobile device, operating at the same 13.56 MHz frequency as Kim’s RFID antenna.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Kim’s wireless charging battery pack with Leizerovich’s NFC teachings to enhance functionality and ensure interoperability. Since NFC was a well-known industry standard for applications like mobile payments (a use-case contemplated by both Kim and Leizerovich), a POSITA would have been motivated to implement Kim’s RFID antenna to support the NFC standard to facilitate such transactions with a wide range of compatible devices.
    • Expectation of Success: Petitioner argued there would be a high expectation of success because Kim’s antenna already operated at the 13.56 MHz frequency used for the NFC standard. The combination would have involved applying known NFC antenna principles to Kim’s existing structure, a predictable task for a POSITA.

Ground 3: Obviousness of Claims 1-3 over Lehr and Chatterjee

  • Prior Art Relied Upon: Lehr (Application # 2013/0308256) and Chatterjee (Patent 8,401,469).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to the Kim-based grounds, Petitioner argued that Lehr in view of Chatterjee renders claims 1-3 obvious. Lehr discloses a mobile computing device with a coil assembly containing a first coil for receiving power and a second coil for data communication. Lehr teaches that the communication coil can circumscribe the power coil. However, Lehr does not explicitly disclose a shielding unit. Chatterjee, which shares inventors with Lehr and is expressly incorporated by reference into Lehr, remedies this by disclosing an "inductive shield" for use in computing devices to protect internal components from magnetic fields generated by such coils.
    • Motivation to Combine: The motivation was argued to be strong and explicit, as Lehr incorporates Chatterjee by reference. A POSITA reading Lehr would naturally look to the teachings of Chatterjee to solve the known problem of electromagnetic interference from the power and communication coils. The combination addresses the need to protect sensitive circuitry within the compact environment of a mobile device.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying Chatterjee’s shield to Lehr’s coil assembly, as Chatterjee provides detailed explanations for implementing such a shield. The result—a shielded, multi-coil wireless power receiver—was argued to be a predictable combination of known elements.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations with Sin (Application # 2012/0068301) for teachings on coil thickness relative to a PCB, and Mochida (Application # 2011/0025265) for teachings on adding a switch to disconnect the communication antenna during wireless charging to prevent interference.

4. Arguments Regarding Discretionary Denial

  • §314(a) (Fintiv Factors): Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court case was in its infancy. Key events such as claim construction, expert discovery, and dispositive motion practice had not yet occurred, and Petitioner contended it had been diligent in filing the IPR petition shortly after receiving infringement contentions.
  • §325(d): Petitioner contended that denial under §325(d) would be inappropriate because the examiner did not previously consider the core prior art or arguments. Several key references (Leizerovich, Lehr, Chatterjee, Sin) were never before the examiner. Although Kim was cited in an Information Disclosure Statement (IDS), it was a Korean-language document for which the examiner was only provided a partial, abstract-level translation, preventing a substantive review. Therefore, Petitioner argued the examiner overlooked or materially erred in not rejecting the claims over Kim.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6, and 7 of the ’364 patent as unpatentable.