Shenzhen Apaltek Co Ltd v. Asetek Danmark AS

1. Case Identification

• Case #: IPR2022-01316
• Patent #: 8,240,362
• Filed: August 1, 2022
• Petitioner(s): Shenzhen Apaltek Co., Ltd.
• Patent Owner(s): Asetek Danmark As
• Challenged Claims: 1, 3-19

2. Patent Overview

• Title: COOLING SYSTEM FOR A COMPUTER SYSTEM
• Brief Description: The ’362 patent relates to a liquid-cooling system for a computer processing unit. The disclosed technology is a compact, integrated cooling solution intended to be more efficient and cost-effective than conventional air-cooling arrangements.

3. Grounds for Unpatentability

Ground 1: Obviousness over Batchelder and Shin - Claims 1, 3-11, 13, and 17-19 are obvious over Batchelder in view of Shin.

• Prior Art Relied Upon: Batchelder (Patent 6,019,165) and Shin (Japanese Unexamined Patent App. Pub. No. 2002-151638).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Batchelder disclosed the core of the claimed invention: an integrated cooling element for a computer component that includes a heat exchanging interface, a pump, and a reservoir. This reservoir, described in Batchelder as an "active spreader plate," was asserted to contain vertically displaced upper and lower chambers separated by a horizontal wall and fluidly coupled by passages. Petitioner contended that Batchelder failed to explicitly disclose an external radiator and fan. To supply these missing elements, Petitioner pointed to Shin, which taught a liquid cooling system where an "integral structure" (analogous to Batchelder's spreader plate) was fluidly coupled via hoses to a separate, external radiator and fan assembly. The combination of Batchelder's integrated pump/reservoir unit with Shin's external heat dissipation system allegedly rendered the limitations of independent claims 1 and 17 obvious.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Shin with Batchelder to improve heat management efficiency. Petitioner asserted that as heat loads from computer components increase, the integrated heat spreader plate in Batchelder would become insufficient on its own. A POSITA would have been motivated to add a well-known component like Shin's external radiator to provide additional cooling capacity, allowing heat to be more efficiently exhausted from the system. This modification was presented as a predictable solution to a known problem.
  • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success in making this combination. The components involved—pumps, reservoirs, radiators, and fans—are standard in the art of liquid cooling. Modifying one of Batchelder's internal fluid flow paths to create an external loop through Shin's radiator was described as a straightforward engineering task with predictable results.

Ground 2: Obviousness over Batchelder, Shin, and Nakano - Claims 12 and 14-16 are obvious over Batchelder and Shin in view of Nakano.

• Prior Art Relied Upon: Batchelder (Patent 6,019,165), Shin (Japanese Unexamined Patent App. Pub. No. 2002-151638), and Nakano (Patent 6,915,653).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Batchelder and Shin from Ground 1 and added Nakano to address limitations related to independent speed control of the pump and fan. Petitioner argued that Nakano disclosed a semiconductor cooling device with a controller that adjusts the speeds of both the refrigerant pump and the condenser fan based on temperature sensor readings. Crucially, Nakano taught that its controller could vary the fan and pump speeds independently, for example, by maximizing fan speed before increasing pump speed, to balance cooling performance with noise levels. This teaching was alleged to render obvious the limitations of claim 12 and claim 14(l), which require that the fan speed be configurable to be varied independent of the pump impeller speed.
  • Motivation to Combine: A POSITA would have been motivated to incorporate Nakano's control system into the Batchelder/Shin combination to achieve improved performance and acoustics. Both cooling efficiency and low noise are common design goals for such systems, as noted in Shin. Nakano provided a known method for achieving these goals by intelligently and independently managing fan and pump speeds. Adding this control logic was argued to be an obvious improvement to the base system proposed in Ground 1.
  • Expectation of Success: Petitioner asserted a reasonable expectation of success because combining familiar elements like a pump, a fan, and a control system using known methods is likely to be obvious and yield predictable results. The integration of Nakano's temperature-based control logic into the electromechanical system of Batchelder/Shin would have been a routine task for a POSITA.

4. Key Claim Construction Positions

• "reservoir": Based on a stipulation in a related district court case, Petitioner proposed construing "reservoir" to mean "single receptacle defining a fluid flow path."
• "chamber": Also based on a stipulation, Petitioner proposed construing "chamber" to mean "compartment within the reservoir."
• "impeller" and "radiator": Petitioner argued these terms should be given their plain and ordinary meaning, as they refer to conventional and well-understood components in the field of thermal management.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1 and 3-19 of the ’362 patent as unpatentable.