PTAB

IPR2023-01264

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 ’310 patent discloses a configurable light emitting diode (LED) driver and dimmer for powering and controlling a set of light fixture loads. The system includes a power circuit, controllers, and an apparatus for mapping output current drivers to various dimming zones and output channels into groups.

3. Grounds for Unpatentability

Ground 1: Anticipation over Shteynberg - Claims 1-2, 8, 10-13, and 16-17 are anticipated by Shteynberg.

  • 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 the challenged claims. Independent claim 1 is met by Shteynberg’s disclosure of a switching power supply for LEDs that is compatible with existing dimmer switches, making it a "configurable LED driver." Petitioner asserted that Shteynberg’s two-stage power supply, comprising an AC/DC converter (265) and a buck converter (270), constitutes the claimed power circuit, apparatus for power factor correction (PFC) and DC/DC conversion, and set of output current drivers. The use of a Negative Temperature Coefficient (NTC) resistor teaches the inrush current limit, and the programmable controller (160, 260) that emulates a dimmer switch to control LED brightness constitutes the apparatus for mapping drivers to dimming zones. For dependent claims, Petitioner argued Shteynberg’s disclosure of "one or more controllers" teaches the secondary controller of claim 2, and the ability to program the controller via hard-wiring implies a port and communication interface (claims 2 and 8).

Ground 2: Anticipation over Morgan - Claims 1-2, 5, 8, 10-12, and 16 are anticipated by Morgan.

  • Prior Art Relied Upon: Morgan (WO 2003/067934).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Morgan’s disclosure of a lighting system with various LED configurations and an addressable controller meets all limitations of independent claim 1. Morgan’s power supply, featuring an integrated PFC (4104) and DC-DC converter (4110), was argued to be the claimed power circuit and apparatus for PFC/DC-DC conversion. A control circuit that adjusts and regulates output teaches the inrush current limit, and the LUC processor (1102) or central controller (202) serves as the primary controller. Petitioner mapped Morgan’s "addressable controller," used to control individual or groups of LEDs, to the claimed "apparatus for mapping." For dependent claims, Petitioner argued that Morgan’s LUC processor can serve as the secondary controller and that its communication port (120) for receiving programming data is the port for mapping required by claim 2. This port, used for programming the device while installed, was asserted to be an in-circuit serial programming (ICSP) port as recited in claim 5.

Ground 3: Obviousness over Shteynberg and Gandhi - Claims 6, 8-9, and 19-20 are obvious over Shteynberg in view of Gandhi.

  • Prior Art Relied Upon: Shteynberg (Patent 7,902,769) and Gandhi (Application # US20120323394).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shteynberg teaches the base configurable LED driver of independent claim 1, and Gandhi supplies the additional features recited in the challenged dependent claims. Specifically, Gandhi's disclosure of a computer interface (130) and a universal asynchronous receiver/transmitter (UART) microchip to receive data from a microcontroller port pin was asserted to teach the "communication interface for receiving data" (claims 6 and 8) and the specific UART limitation (claim 9). Further, Petitioner contended that Gandhi’s LED driver circuit—which includes a slave microcontroller (U30) as a load controller, integrated circuits (U1111-U1113) as a current source, and sense resistors (R1111-R1113) as a current sense—teaches the limitations of claim 19. The signal processing circuitry in Gandhi was argued to teach the "signal generator" of claim 20.
    • Motivation to Combine: A POSITA would combine Shteynberg and Gandhi because they are analogous art in the field of LED drivers and address the same technical problems. A POSITA would have been motivated to incorporate Gandhi’s well-known communication and control components into Shteynberg’s foundational driver design to add functionality, such as enhanced external control and more precise current regulation, which were known improvements in the field.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success, as the integration of standard components like a UART interface and current-sensing circuits from Gandhi into the power supply architecture of Shteynberg was a straightforward application of known engineering principles.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise discretionary denial under Fintiv. The petition asserted that all Fintiv factors are either neutral or weigh in favor of institution, citing the early stage of the parallel district court litigation, the distant trial date, the strong merits of the unpatentability challenges, and the use of prior art that was not before the examiner during prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 5-6, 8-13, 16-17, and 19-20 of the ’310 patent as unpatentable.