PTAB

IPR2023-01259

Advanced Lighting Concepts LLC v. Mate LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus, System and Method for Limiting Power in a Solid State Lighting Device
  • Brief Description: The ’713 patent discloses an apparatus and system for monitoring and limiting power supplied to a solid-state lighting (SSL) device. The system is designed to detect an operational fault condition, such as when the power level meets or exceeds a predetermined limit, and then reduce the power supplied to the SSL device to mitigate risks like overheating or fire hazards.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, 5, 10, and 13 by Zudrell-Koch

  • Prior Art Relied Upon: Zudrell-Koch (Patent 9,173,273)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zudrell-Koch, which teaches a driver circuit for controlling SSL devices, disclosed every limitation of independent claim 1. Specifically, Petitioner contended that Zudrell-Koch’s “driver circuit” is the claimed “power circuit,” and its “control unit” configured to determine if an input voltage exceeds a threshold is the claimed “power limit controller.” Petitioner asserted that the “input Voltage pin” on Zudrell-Koch’s control unit, which monitors voltage, is analogous to the claimed “power limit.” Zudrell-Koch’s control unit monitors this voltage (the load power) and, upon exceeding a threshold, controls the current through a switch, thereby reducing the load power as claimed. The petitioner further argued that Zudrell-Koch’s use of a feedback signal from a sensing resistor, which is processed by the control unit to manage current, constituted the claimed generation of a signal based on internal controls to manage load power. For the dependent claims, Petitioner argued that Zudrell-Koch’s integrated control unit met the integration requirement of claim 2, its disclosure of a current source and current sensing means met the elements of claim 5, its use of a pulse-width modulated signal met the “pulsing technique” of claim 10, and its explicit mention of driving an “LED or an OLED” met the load types of claim 13.

Ground 2: Obviousness of Claims 12 and 13 over Zudrell-Koch in view of Zhdanau or Veskovic

  • Prior Art Relied Upon: Zudrell-Koch (Patent 9,173,273), Zhdanau (Application # US2014/0103804), and Veskovic (Application # US2013/0063047)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that if Zudrell-Koch does not anticipate claims 12 and 13, they are rendered obvious by its combination with either Zhdanau or Veskovic. Petitioner argued that Zudrell-Koch teaches the base system of claim 1, as established in Ground 1. For claim 12, which requires reducing load power by a "constant current reduction technique," Petitioner contended that both Zhdanau and Veskovic explicitly taught this method. Zhdanau disclosed using LED module controls to manage the current and brightness of individual LEDs, and Veskovic described a controller that regulates the average magnitude of load current to a target value. A person of ordinary skill in the art (POSITA) would have found it obvious to apply these conventional current control techniques to the power-limiting system of Zudrell-Koch. For claim 13, which specifies the SSL load is an OLED, LED, or LED array, Petitioner argued that both Zhdanau (describing long lengths of LED lighting) and Veskovic (describing an LED driver for an LED light source) made it obvious to use Zudrell-Koch’s driver with these common SSL loads.
    • Motivation to Combine: Petitioner argued that a POSITA would combine these references because they are all analogous art from the same field of endeavor—LED drivers. All three references are directed to powering and controlling SSL applications and address the common problem of managing power and current delivered to an LED load. A POSITA would have been motivated to incorporate the well-known constant current control methods of Zhdanau or Veskovic into the protective circuit of Zudrell-Koch to achieve predictable and stable power reduction.
    • Expectation of Success: Petitioner asserted a high expectation of success because the components and techniques described in all references were well-known at the time. Combining a known power-limiting circuit (Zudrell-Koch) with a standard current reduction technique (Zhdanau or Veskovic) for a standard LED load was a straightforward design choice with predictable results.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not discretionarily deny institution under Fintiv based on a parallel district court litigation. Petitioner contended that the Fintiv factors favor institution or are neutral: no stay has been granted; the trial date is distant, occurring well after the deadline for a Final Written Decision (FWD); the parallel litigation is in its early stages with minimal investment; the FWD would likely trigger estoppel and streamline the district court case; and the unpatentability challenges are compelling and rely on references not previously considered by the USPTO.

5. Relief Requested

  • Petitioner requests that the Board institute an inter partes review and cancel claims 1, 2, 5, 10, 12, and 13 of the ’713 patent as unpatentable.