Samsung Electronics Co Ltd v. Mojo Mobility LLC

1. Case Identification

• Case #: IPR2023-01093
• Patent #: 11,201,500
• Filed: June 28, 2023
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Mojo Mobility Inc.
• Challenged Claims: 2, 4, 18

2. Patent Overview

• Title: System for Inductive Powering or Charging
• Brief Description: The ’500 patent describes a system for the wireless inductive charging of portable electronic devices. The disclosed technology involves a power transmitter with one or more primary coils and a portable device with a receiver unit, which communicate to control and regulate the power transfer process.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 2 over a Core Combination in view of Masias

• Legal Basis: Claim 2 is obvious under 35 U.S.C. §103 over Okada in view of Odendaal, Berghegger, Black, and Masias.
• Prior Art Relied Upon: Okada (Japanese Application # 2006-141170A), Odendaal (Patent 6,960,968), Berghegger (Patent 6,912,137), Black (Application # 2006/0145660A1), and Masias (Patent 7,339,353).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Okada disclosed a foundational inductive charging system capable of selecting a power level at the onset of charging based on device information. The combination with other references allegedly rendered all limitations of parent claim 1 obvious. Odendaal was cited for its teaching of using substantially planar coils to create thinner and more efficient charging systems. Berghegger was cited for disclosing a closed-loop feedback system that adjusts power delivery during the charging process based on the device's real-time power demand. Black was cited for teaching the communication of charging algorithm profiles to intelligently control charging operations and prevent overcharging. For the specific limitations of dependent claim 2, Petitioner argued that Masias taught a power source system with voltage regulator circuits that provide multiple, customizable voltage levels to accommodate the different power requirements of various devices.
  • Motivation to Combine: A POSITA would combine these references to improve upon Okada's basic system. The motivation was to create a more efficient, intelligent, and versatile charger by integrating known solutions: Odendaal's planar coils for a better form factor, Berghegger's dynamic power adjustment for efficiency, Black's charging profiles for battery health, and Masias's voltage regulators for compatibility with a wider range of devices.
  • Expectation of Success: A POSITA would have an expectation of success because the combination involved applying well-known technologies within the same field of wireless power transfer to achieve the predictable result of an enhanced charging system.

Ground 2: Obviousness of Claim 4 over a Core Combination in view of Calhoon

• Legal Basis: Claim 4 is obvious over Okada in view of Odendaal, Berghegger, Black, and Calhoon.
• Prior Art Relied Upon: Okada (Japanese Application # 2006-141170A), Odendaal (Patent 6,960,968), Berghegger (Patent 6,912,137), Black (Application # 2006/0145660A1), and Calhoon (Application # 2005/0127868A1).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground relied on the same core combination of Okada, Odendaal, Berghegger, and Black as Ground 1 to meet the limitations of parent claim 1. Claim 4 adds the requirement that the system receive specific identification information, including manufacturer codes, unique device ID codes, a charge algorithm profile, and power requirements. Petitioner argued that the core combination already taught receiving power requirements (Okada, Berghegger) and charge profiles (Black). Calhoon was added to explicitly teach a system where an inductive charger receives a manufacturer's name and unique serial number from a device for purposes of security, data integrity, and authentication.
  • Motivation to Combine: A POSITA would combine Calhoon's teachings to add a layer of security and device-specific identification to the charging system. This would allow the charger to authenticate a device before providing power, improving security and enabling more tailored charging profiles, which was a known benefit in the art.
  • Expectation of Success: Integrating device identification and authentication methods from Calhoon into a wireless charging system was a straightforward application of known data communication techniques, leading to a predictable improvement in system security and functionality.

Ground 3: Obviousness of Claim 18 over a Core Combination in view of Kazutoshi

• Legal Basis: Claim 18 is obvious over Okada in view of Odendaal, Berghegger, Black, and Kazutoshi.
• Prior Art Relied Upon: Okada (Japanese Application # 2006-141170A), Odendaal (Patent 6,960,968), Berghegger (Patent 6,912,137), Black (Application # 2006/0145660A1), and Kazutoshi (Application # 2005/0135129A1).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground also relied on the core combination of Okada, Odendaal, Berghegger, and Black to establish the features of parent claim 1, including a closed-loop feedback control system for regulating power. Claim 18 further requires that this regulation use a "Proportional-Integral-Derivative (PID) control technique." While the core combination taught closed-loop regulation, Petitioner argued it would have been obvious to implement this using a standard PID controller, as explicitly taught by Kazutoshi. Kazutoshi disclosed a contactless power supply system that used a PID controller to regulate the output current provided to a load.
  • Motivation to Combine: A POSITA seeking to implement the closed-loop feedback taught by Berghegger would be motivated to use a PID controller because it is a well-known, standard, and highly effective technique for precise regulation in control systems. Kazutoshi demonstrated the direct applicability of PID control to the field of contactless power transfer.
  • Expectation of Success: Applying a standard PID control algorithm, as taught by Kazutoshi, to the feedback loop of the combined Okada/Berghegger system was a well-understood engineering choice that would predictably result in a more stable and accurately regulated power output.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §325(d), contending the examiner erred by not considering the primary reference, Okada, in combination with the other asserted prior art and did not have the benefit of expert testimony explaining these combinations.
• Petitioner also argued that discretionary denial under Fintiv is inappropriate. It asserted that the district court case is in its early stages with minimal investment, the proximity to trial is neutral, and Petitioner has stipulated it will not pursue the same grounds in district court if the IPR is instituted. Petitioner contended these factors, combined with the compelling merits of the petition, weigh strongly in favor of institution.

5. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 2, 4, and 18 of Patent 11,201,500 as unpatentable.