Samsung Electronics Co Ltd v. Mojo Mobility LLC

1. Case Identification

• Case #: IPR2023-01094
• Patent #: 11,316,371
• Filed: June 30, 2023
• Petitioner(s): Samsung Electronics Co., Ltd.
• Patent Owner(s): Mojo Mobility Inc.
• Challenged Claims: 1-4, 8, and 11-12

2. Patent Overview

• Title: Inductive Power and Charging System
• Brief Description: The ’371 patent relates to an apparatus for inductively providing power to portable electronic devices. The system uses a communication and control circuit to manage power transfer based on information received from the portable device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Okada, Odendaal, Kook, Calhoon, and Black - Claims 1 and 4 are obvious

• Prior Art Relied Upon: Okada (Japanese Application Publication No. 2006-141170A), Odendaal (Patent 6,960,968), Kook (Application # 2009/0261778), Calhoon (Application # 2005/0127868), and Black (Application # 2006/0145660).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Okada taught the foundational wireless charging apparatus, including a power transmitting module and a power receiving module in a portable device. However, Okada did not explicitly disclose certain features. Petitioner argued that Odendaal taught the use of substantially planar and parallel primary coils to create thinner charging units. Kook was cited for teaching a closed-loop feedback system using a capacitor-based filter in the drive circuit to control power transfer by varying operating frequency in response to current feedback, thereby improving efficiency and reducing harmonics. Calhoon was alleged to disclose communicating unique device identifiers and manufacturer codes for authentication, while Black taught communicating a specific "charge algorithm profile" to control charging operations based on battery characteristics.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the base system of Okada with the known, advantageous features from the other references. A POSITA would incorporate Odendaal’s planar coils to achieve a more desirable, thin form factor. Kook's feedback control would be added to improve power transmission efficiency and stability, a known problem in the art. Finally, a POSITA would integrate the advanced communication protocols from Calhoon and Black to enhance device verification, security, and charging safety, which were all well-known goals in mobile device charging.
  • Expectation of Success: The combination involved applying known technologies for their predictable purposes. Implementing planar coils, feedback control, and specific charging profiles were all established techniques in the field of wireless power, and a POSITA would have had a reasonable expectation of successfully integrating them to create the claimed system.

Ground 2: Obviousness over Okada, Odendaal, Kook, Calhoon, Black, and Kazutoshi - Claim 2 is obvious

• Prior Art Relied Upon: The references from Ground 1, plus Kazutoshi (Application # 2005/0135129).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground specifically targeted claim 2, which recites that the closed-loop feedback manner comprises a Proportional-Integral-Derivative (PID) control technique. Petitioner argued that while the primary combination established the motivation for closed-loop feedback control, Kazutoshi explicitly taught using a PID controller to regulate voltage and current in a contactless power supply system.
  • Motivation to Combine: A POSITA, seeking to implement the stable and efficient closed-loop feedback system suggested by the primary references, would have been motivated to use a well-known and effective control method. PID control was a standard, predictable solution for regulating system outputs, and Kazutoshi demonstrated its application in the same technical field. Therefore, using a PID controller would be an obvious design choice to implement the feedback loop.
  • Expectation of Success: Given that PID controllers were a textbook solution for process control and Kazutoshi showed their use in a directly analogous system, a POSITA would have had a high expectation of success in applying this technique to the primary combination.

Ground 3: Obviousness over Okada, Odendaal, Kook, Calhoon, Black, and Labrou - Claim 12 is obvious

• Prior Art Relied Upon: The references from Ground 1, plus Labrou (Application # 2007/0022058).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addressed claim 12, which adds limitations for a magnetic core of ferromagnetic material and a Near Field Communication (NFC) antenna and circuitry. Petitioner contended Kook already taught using a ferrite core with a primary coil to improve efficiency. Labrou was added to teach the integration of an NFC chip, including an antenna and circuitry, into a mobile device to enable wireless data communication for applications like point-of-sale transactions.
  • Motivation to Combine: A POSITA would be motivated to improve the magnetic coupling and efficiency of the planar coil by adding a ferrite core, a known technique taught by Kook. Furthermore, integrating NFC capabilities, as taught by Labrou, was a common and desirable feature for portable devices to add functionality. A POSITA would have found it obvious to include this standard communication technology in the claimed apparatus.
  • Expectation of Success: Adding a ferrite core and an NFC chip were routine modifications for improving wireless charging efficiency and device functionality, respectively. Both involved combining known components for their intended, predictable results.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations incorporating Masias (Patent 7,339,353) to teach a voltage regulator for providing multiple discrete voltage levels, and Chen (Application # 2005/0270745) to teach a high heat conductivity layer for thermal management.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §325(d), stating the examiner erred by not considering the primary reference, Okada, in combination with the other asserted art and did not have the benefit of expert testimony.
• Petitioner also argued against discretionary denial under Fintiv, asserting that the district court case is in its early stages with minimal investment, a trial is not imminent relative to the Final Written Decision (FWD) deadline, and Petitioner stipulated it would not pursue the same grounds in district court if the inter partes review (IPR) is instituted.

5. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-4, 8, and 11-12 of the ’371 patent as unpatentable.