PTAB

IPR2023-01257

Advanced Lighting Concepts LLC v. Mate LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Configurable LED Driver/Dimmer
  • Brief Description: The ’446 patent discloses a configurable light emitting diode (LED) driver/dimmer for controlling light fixture loads. The system includes a power circuit, a primary digital controller for the power circuit, a set of output current drivers, and a secondary digital controller that controls the drivers and provides feedback to the primary controller.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 13, 15, and 21 under 35 U.S.C. §102

  • Prior Art Relied Upon: Shteynberg (Patent 7,902,769).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shteynberg, which teaches a system for supplying power to solid-state lighting devices, discloses every limitation of independent claims 1 and 21. Petitioner asserted that Shteynberg’s two-stage switching power supply, comprising an AC/DC converter (265) and a buck converter (270), constitutes the claimed power circuit, including an inrush current limit, a DC/DC converter, a built-in power factor correction (PFC) boost, a regulated output voltage bus, and a power limit. Petitioner contended that Shteynberg’s controller (160, 260) meets the limitations for both a primary controller (controlling the power circuit) and a secondary controller (controlling output drivers and transmitting control information). For dependent claims, Petitioner argued Shteynberg’s disclosure of powering LEDs meets the LED load limitation of claim 13, and its disclosure of digital processors and microprocessors meets the digital controller limitation of claim 15.

Ground 2: Obviousness of Claims 2, 3, 5, and 7 under 35 U.S.C. §103

  • Prior Art Relied Upon: Shteynberg (Patent 7,902,769) and Morgan (Application # US20060022214).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that to the extent Shteynberg does not teach the limitations of dependent claims 2, 3, 5, and 7, Morgan provides the missing elements. Specifically, Petitioner asserted that Morgan discloses a set of serial programming ports (e.g., USB, Ethernet) for configuring output current drivers, meeting the in-circuit serial programming (ICSP) port limitation of claim 2. Morgan further teaches a communication interface for receiving data from an external system (e.g., a computer) and transmitting it to a controller, as required by claim 3. Petitioner also contended that Morgan’s disclosure of various network protocols (e.g., DMX, 802.11 wireless) would render it obvious to implement the specific communication interfaces of claim 5 (e.g., DMX512A, Zigbee wireless). Finally, Petitioner argued Morgan’s disclosure of various housings (800) for lighting unit components meets the housing limitation of claim 7.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Shteynberg and Morgan because both references are in the same field of endeavor (LED drivers) and are analogous art pertinent to the problem of powering and controlling solid-state lighting. A POSITA would have sought to add the advanced control, programming, and communication features taught by Morgan to Shteynberg’s fundamental power supply architecture to create a more versatile and configurable product.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in combining the references. The components described in both Shteynberg and Morgan were well-known in the art at the time, making the modification of Shteynberg’s LED driver to include Morgan’s features straightforward.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. §314(a) based on the Fintiv factors. Petitioner asserted that the parallel district court litigation is in its early stages, with discovery having just begun and no claim construction briefs filed. Petitioner noted that no stay has been requested or granted. It was argued that the early stage of the co-pending litigation, the compelling nature of the unpatentability challenges, and the strong public interest in canceling invalid patents all weigh heavily in favor of institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-3, 5, 7, 13, 15, and 21 of the ’446 patent as unpatentable.