PTAB

IPR2023-01089

Samsung Electronics Co Ltd v. Mojo Mobility LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Inductive Power Transfer System
  • Brief Description: The ’349 patent relates to a system and method for inductively transferring power from a charger to one or more receivers, such as mobile devices. The invention focuses on the configuration of charger coils, receiver solenoids, and magnetic layers to facilitate efficient power transfer.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fells - Claims 1, 5, 7, 10-12, and 26 are obvious over Fells.

  • Prior Art Relied Upon: Fells (Patent 8,587,154).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fells, which describes an inductive power transfer system, discloses all limitations of independent claims 1 and 26. Fells teaches a system with a primary unit (charger) having planar spiral coils on a printed circuit board with a ferrite back-plate (magnetic layer) and a secondary device (receiver) containing a solenoid with a magnetic core. Petitioner asserted Fells discloses a charger drive circuit with FET switches and resonant capacitors, and a receiver circuit with a rectifier and resonant capacitor, which together form a tuned circuit for power transfer. For the "means for positioning" limitation, Petitioner contended that Fells’ disclosure of a charger configured as a "shelf" or "ledge" that ensures alignment in one dimension constitutes the claimed physical means.
    • Motivation to Combine (for §103 grounds): Not applicable, as this is an anticipation-style obviousness argument over a single reference. However, for the "means for positioning," Petitioner argued in the alternative that if Fells’ shelf was not considered sufficient, a person of ordinary skill in the art (POSITA) would have been motivated to modify Fells’ charger with well-known mechanical, magnetic, or visual alignment aids to improve coupling and power transfer efficiency, a predictable and known solution to a common problem.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in applying known alignment aids to Fells' system, as it involved implementing known techniques to achieve their intended, predictable function of improving device alignment.

Ground 2: Obviousness over Fells and Jung - Claim 4 is obvious over Fells in view of Jung.

  • Prior Art Relied Upon: Fells (Patent 8,587,154) and Jung (Patent 9,178,376).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Fells-based arguments for claim 1, from which claim 4 depends. Petitioner argued that while Fells teaches all elements of the power transfer system, it does not explicitly disclose a power transfer efficiency exceeding 50% as defined in claim 4. Jung, however, explicitly addresses improving power transmission efficiency in similar inductive charging systems and describes achieving efficiencies exceeding 50% (e.g., 53% and 60%).
    • Motivation to Combine (for §103 grounds): A POSITA would combine Fells with Jung because both references are in the same field of endeavor and address the common problem of efficient inductive power transfer. Petitioner asserted a POSITA would have been motivated to configure the Fells system to operate with the high efficiency levels taught by Jung to minimize energy loss, a predictable and desirable goal in power system design.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in achieving over 50% efficiency by applying Jung’s teachings, as it involved optimizing known system parameters to achieve a known benefit.

Ground 3: Obviousness over Fells, Stoner, and Nakamura - Claims 1, 5, 7, 10-12, and 26 are obvious over Fells in view of Stoner and Nakamura.

  • Prior Art Relied Upon: Fells (Patent 8,587,154), Stoner (Patent 8,912,686), and Nakamura (Application # 2005/0068019).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground provided an alternative argument for the "means for positioning" limitation of claims 1 and 26. Petitioner argued that even if Fells's physical ledge was insufficient, the addition of magnetic or visual alignment mechanisms to Fells's system would have been obvious. Stoner and Nakamura were presented as evidence that using such alignment aids (e.g., magnets, visual guides) was well-known in the art of inductive charging at the time of the invention.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Fells with the teachings of Stoner and Nakamura to solve the known problem of receiver misalignment on a charging surface. Adding a magnetic or visual alignment mechanism as taught by Stoner and Nakamura to the Fells system was argued to be a simple, well-understood design choice to ensure proper and efficient coupling.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected that adding known alignment mechanisms to the Fells system would predictably result in improved alignment and more efficient charging.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 4 based on the combination of Fells, Stoner, Nakamura, and Jung, incorporating the arguments from the grounds above.

4. Key Claim Construction Positions

  • Petitioner argued that the term "means for positioning..." recited in claims 1(k) and 26(e) is a means-plus-function term under 35 U.S.C. §112(f).
    • Function: "positioning [the/a] receiver in a power transfer position, [which is] proximate to the charger surface, to inductively transfer power to the receiver."
    • Corresponding Structure: The structure disclosed in the specification, including "visual, physical, or magnetic means to assist the user in alignment of parts," and specifically "one or more magnets" as recited in dependent claim 24. This construction is central to Petitioner's arguments that the prior art either discloses or renders obvious this limitation.

5. Arguments Regarding Discretionary Denial

  • §325(d): Petitioner argued against discretionary denial under 35 U.S.C. §325(d), asserting that the prior art and arguments presented are not the same or substantially similar to those before the examiner during prosecution. Petitioner noted that Fells, Jung, and Stoner were never considered by the examiner. While Nakamura was cited in an IDS, it was never applied or considered in combination with other art, representing a material error by the examiner.
  • Fintiv: Petitioner argued against discretionary denial under Fintiv, contending that the factors weigh in favor of institution. Petitioner stated that the co-pending district court case is in its early stages, with minimal investment, as fact discovery is not yet complete and expert discovery has not begun. Petitioner also stipulated that it will not pursue the same grounds in district court if the IPR is instituted, weighing against denial.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4-5, 7, 10-12, and 26 of Patent 11,292,349 as unpatentable.