PTAB

IPR2023-01258

Advanced Lighting Concepts LLC v. Mate LLC

Key Events

Petition

petition Intelligence

Title: Configurable LED Driver/Dimmer
Brief Description: The ’759 patent describes a configurable light-emitting diode (LED) driver for powering a set of light fixture loads. The driver includes a power circuit with features such as an inrush current limit, a DC/DC converter, a power factor correction (PFC) boost, a primary controller, and a set of configurable output current drivers.

Prior Art Relied Upon: Shteynberg (Patent 7,902,769).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Shteynberg discloses every limitation of independent claims 1 and 20. Shteynberg's switching power supply, which includes a two-stage AC/DC converter and a buck converter, was asserted to teach the claimed "power circuit" with a "DC/DC converter." Petitioner contended that Shteynberg’s disclosure of using a Negative Temperature Coefficient (NTC) resistor to minimize inrush current teaches the "inrush current limit." Further, Shteynberg’s power stage with a "built-in capability to deliver power factor correction" was argued to disclose the "PFC boost connected to the inrush current limit and the DC/DC converter." Petitioner mapped Shteynberg’s controller (160/260), which modifies brightness by controlling the switching power supply, to the claimed "primary controller" and the "apparatus for configuring the set of output current drivers." The dependent claims were also allegedly disclosed, with Shteynberg’s description of a controller comprising a "plurality of integrated circuits" teaching the "secondary controller" of claim 6.

Prior Art Relied Upon: Shteynberg (Patent 7,902,769) and Kim (Application # US20120007512).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Shteynberg teaches the base LED driver system of independent claim 1. Kim was introduced to supply the additional limitations of the challenged dependent claims. For claim 2, Petitioner argued that Kim’s disclosure of an "LED driving unit" supplying power to multiple LED units would inherently require a port for configuration, as claimed. For claim 5, Kim's teaching of controlling the constant current flowing to LED lamps was presented as analogous to "programming the output current set point." For claim 15, Petitioner contended that Kim’s disclosure of a power supply device with a power factor correction unit and a current balancing unit teaches the claimed limitation of an "output voltage bus connected to at least one power limit."
- Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Shteynberg and Kim because both are analogous art directed to LED drivers and address similar technical problems of powering and controlling solid-state lighting.
- Expectation of Success: A POSITA would have a reasonable expectation of success in the combination because the components and functionalities described in both references were well-known, making their integration straightforward.

Prior Art Relied Upon: Shteynberg (Patent 7,902,769) and Morgan (Application # US20060022214).
Core Argument for this Ground:
- Prior Art Mapping: As in Ground 2, Petitioner relied on Shteynberg for the foundational elements of the challenged claims. Morgan was introduced to teach additional features. For claims 8 and 9, Petitioner argued that Morgan’s disclosure of lighting systems with "DMX interfaces" and other "lighting unit interfaces" teaches the claimed "communication interface" for receiving data, including DMX512A compatibility. For claim 16, Morgan’s express teaching of an electronic component being a "buck converter" was asserted to supply the limitation that the output current drivers comprise a "buck topology power converter." For claims 17 and 24, Morgan’s description of various housings for lighting fixtures was argued to render obvious the inclusion of a "housing portion for housing the components of the driver."
- Motivation to Combine: A POSITA would combine Shteynberg and Morgan as they are in the same field of endeavor (LED drivers) and are reasonably pertinent to the problems of controlling and packaging LED lighting systems.
- Expectation of Success: Petitioner asserted a high expectation of success, as modifying Shteynberg’s driver to include standard features like the communication interfaces and housings taught by Morgan would have been a simple and predictable design choice.

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 contended that the merits of the petition are strong, and the factors weigh in favor of institution or are neutral. Key arguments included that no stay has been granted in the parallel district court litigation, the trial date is not imminent, the court case is in its early stages, and the prior art references relied upon in the petition were not before the USPTO during the original prosecution.

Petitioner requested institution of an inter partes review and cancellation of claims 1, 5, 6, 9, 13, 15-17, 19, 20, and 24 of the ’759 patent as unpatentable.