PTAB

IPR2023-01265

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 ’093 patent discloses a configurable light emitting diode (LED) driver and dimmer for powering and controlling a set of light fixture loads in a low-voltage distribution system. The technology aims to provide flexible and efficient control over solid-state lighting applications by converting and limiting power, processing external control signals, and managing multiple current outputs to the LEDs.

3. Grounds for Unpatentability

Ground 1: Anticipation over Leong - Claims 1-2, 9-13, and 19-20 are anticipated by Leong under 35 U.S.C. §102.

  • Prior Art Relied Upon: Leong (Patent 7,490,957).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Leong, which discloses a power-saving device for an LED lamp, teaches every limitation of independent claims 1 and 11. Leong was shown to disclose a method of configuring and powering LED light fixture loads by describing a "means for controlling the delivery of electrical power." Petitioner mapped specific claim elements to Leong's teachings, including: converting AC to DC voltage using bridge rectifiers (meeting the "converting power" limitation); using voltage surge absorbers and resistors to limit voltage and current (meeting the "limiting converted power" limitation); dividing total current among multiple LED strings (meeting the "splitting or regrouping" limitation); and receiving wireless or hard-wired data control signals (e.g., WiFi, DMX512) from an external transmitter, which are then decoded by a dimmer to provide the proper current drive power (meeting the "receiving a protocol," "translating the data stream," and "using control information for controlling the limited power" limitations). Arguments for dependent claims followed from this primary mapping.

Ground 2: Obviousness over Leong and Lee - Claims 5-7 and 15-17 are obvious over Leong in view of Lee under 35 U.S.C. §103.

  • Prior Art Relied Upon: Leong (Patent 7,490,957) and Lee (Application # 2015/0097484).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that while Leong teaches the base limitations of independent claims 1 and 11, Lee supplies the additional limitations found in dependent claims 5-7 and 15-17. Specifically, claims 5 and 15 require "receiving power via a set of input channels." Petitioner argued Lee discloses this limitation by describing an LED driving module with a "driving voltage input terminal VP" and a "dimming level signal input terminal Adim," which a POSITA would understand as a set of input channels. Claims 6, 7, 16, and 17 add limitations for "delivering power...via a set of output channels" and "splitting the set of input channels into the set of output channels." Lee was argued to disclose these limitations through its description of multiple current paths (P1-P4) connected to various connection terminals (ST1-ST4) that deliver power to different LED groups, which a POSITA would recognize as a set of output channels derived from the inputs.
    • Motivation to Combine: Petitioner contended that a POSITA would combine Leong and Lee because they are analogous arts in the same field of endeavor: LED drivers and controllers for solid-state lighting applications. Both references address the pertinent technical problem of powering and controlling LEDs. A POSITA would have sought to incorporate the specific input/output channel configurations of Lee into the comprehensive control system of Leong to create a more versatile and structured LED driver.
    • Expectation of Success: Petitioner argued there was a reasonable expectation of success because the LED driver components and circuit configurations described in both Leong and Lee were well-known at the time. Modifying Leong’s driver to include Lee’s specific methods for receiving power via input channels and delivering it via distinct output channels would have been a straightforward integration of known elements to achieve a predictable result.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not discretionarily deny institution under the Fintiv factors. It was contended that Factor 1 (Stay) is neutral as no stay has been requested or granted in the parallel district court litigation. Factor 2 (Proximity of Trial Date) was argued to favor institution, as the projected trial date is well after the statutory deadline for a Final Written Decision. Factors 3 (Investment) and 4 (Overlap) were also argued to favor institution because the parallel litigation is in its early stages with minimal investment, and an FWD would promote efficiency and estoppel. Factor 5 (Same Parties) is neutral. Finally, Factor 6 (Other Circumstances) was argued to be dispositive in favor of institution because the petition’s unpatentability challenges are compelling, rely on art not before the examiner, and serve the public interest against leaving potentially invalid patents enforceable.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-2, 5-7, 9-13, 15-17, and 19-20 of the ’093 patent as unpatentable.