PTAB

IPR2023-01266

Advanced Lighting Concepts LLC v. Mate LLC

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1. Case Identification

2. Patent Overview

  • Title: Configurable Light Emitting Diode (LED) Driver/Dimmer
  • Brief Description: The ’601 patent discloses a configurable power system for low-voltage LED lighting. The system comprises an LED driver that provides power to a separate "break-out module," which in turn distributes power to a set of distinct light fixture loads, allowing for flexible configuration.

3. Grounds for Unpatentability

Ground 1: Anticipation over Peng - Claims 1, 10, 11, 14, and 15 are anticipated by Peng.

  • Prior Art Relied Upon: Peng (Application # 2007/0267984).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Peng discloses every limitation of independent claims 1 and 15. Peng’s “isolated dimmable LED ballast driver” was asserted to be the claimed LED driver. Its “LED ballast circuit” was argued to be analogous to the claimed “break-out module” as it receives power and distributes it to the LED loads. Petitioner contended that Peng’s “overload-protection feature” taught the claimed “power limit,” and its power conditioning unit, including driver 605, disclosed the “set of output current drivers.” The physical separation of Peng’s dimmer controller from the lighting unit was argued to meet the limitation of the driver being located remotely from the light fixture loads.
    • Key Aspects: The core of this argument relied on equating Peng’s ballast-based architecture with the driver and break-out module architecture of the ’601 patent.

Ground 2: Anticipation over Leong - Claims 1, 11-12, 15, and 17 are anticipated by Leong.

  • Prior Art Relied Upon: Leong (Application # 2005/0162101).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Leong, which describes an LED lamp for retrofitting fluorescent fixtures, discloses all elements of the challenged claims. Leong’s “dimming module” or “current driver dimmer” was mapped to the claimed “LED driver,” and its pre-existing “ballast assembly” was mapped to the “break-out module.” Petitioner argued that Leong’s power control modules and dimming controller taught the claimed power circuit with a power limit. The ability of Leong’s ballast to power multiple lamps in parallel was argued to teach the splitting of input channels into individual output channels. For dependent claim 12, Leong’s disclosure of receiving an external data control signal via a power line or wireless communication was argued to teach a communication interface.

Ground 3: Obviousness over Peng or Leong in view of Bornhurst - Claims 2-5, 8, and 10 are obvious over Peng or Leong in view of Bornhurst.

  • Prior Art Relied Upon: Peng (Application # 2007/0267984) or Leong (Application # 2005/0162101), in view of Bornhurst (Patent 5,640,061).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that while Peng and Leong provide the core LED driver and power distribution system, Bornhurst supplies the specific cabling and connection features recited in the dependent claims. Bornhurst discloses a modular power supply system for stage lighting, including a multi-circuit trunk cable connecting a power supply chassis to a “break-out box,” which then connects to individual luminaires via separate lamp cables. Petitioner contended this expressly teaches connecting output current drivers to a break-out module via cabling (claim 2), using series connect modules (claim 3), and having the cabling include input channels (claim 4), as well as enabling quick connection and release (claim 8).
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine the teachings of Bornhurst with the systems of Peng or Leong to achieve a robust, modular, and easily configurable lighting system. Bornhurst provided a well-understood, conventional method for distributing power in a lighting rig, making its application to the LED systems of Peng or Leong a simple and predictable design choice to improve modularity and serviceability.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved applying a conventional power distribution and cabling solution (Bornhurst) to a known type of power supply (Peng or Leong).

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 12 based on Peng or Leong in view of Slot (Application # 2008/0191642), and an anticipation challenge against claim 1 based on Shteynberg (Patent 7,902,769).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under the Fintiv factors would be inappropriate. The core arguments were that the parallel district court litigation is in a very early stage with no claim construction briefs filed and a trial date not expected until April 2026, well after the statutory deadline for a Final Written Decision. Petitioner further asserted that the challenges are compelling, rely on prior art not considered during prosecution, and that institution serves the strong public interest in canceling invalid patent claims.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-5, 8, 10-12, 14, 15, and 17 of the ’601 patent as unpatentable.