PTAB

IPR2024-00140

InductEV Inc v. WiTricity Corp

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless High Power Transfer Under Regulatory Constraints
  • Brief Description: The ’654 patent describes a system for wirelessly charging a battery-operated vehicle by transferring power between a primary (transmitting) coil and a secondary (receiving) coil. The technology focuses on using matched resonance and includes mechanisms for actively aligning the coils to achieve better magnetic coupling and improve power transfer efficiency.

3. Grounds for Unpatentability

Ground 1: Anticipation by Movable Transmitter System - Claims 13 and 15 are unpatentable under 35 U.S.C. §102 over Odachi.

  • Prior Art Relied Upon: Odachi (Patent 5,617,003).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Odachi, which teaches a wireless vehicle charger, anticipates every element of claims 13 and 15. Odachi disclosed guiding a vehicle’s receiving antenna to a first alignment position by parking it against wheel stops. It then detected the degree of coupling by measuring the induced voltage (VRMS) across the secondary coil while its movable transmitting antenna performed a sweep. Based on this measurement, Odachi’s controller calculated an optimal "target position" and moved the transmitting antenna to this second, better-aligned position, thereby improving the coupling.

Ground 2: Obviousness with Resonant Circuits - Claims 1, 7, and 18 are obvious over Odachi in view of Wang.

  • Prior Art Relied Upon: Odachi (Patent 5,617,003) and Wang (a 2004 Ph.D. dissertation on inductively coupled power transfer).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Odachi disclosed the core system of aligning a movable transmitting antenna with a vehicle's receiving antenna based on coupling measurements. While Odachi was silent on using resonant circuits, Wang taught that inductively coupled power transfer (ICPT) systems for high-power applications like vehicle charging were commonly "compensated" by adding capacitors to the primary and secondary coils. This modification would create resonant circuits that operate at a specific frequency, meeting the limitations of the challenged claims.
    • Motivation to Combine: A POSITA would combine Wang’s teaching with Odachi’s system to achieve the predictable result of increased power transfer capability and efficiency. Wang explicitly stated that compensating coils with capacitors "boost[s] the power transfer capability," a well-known solution to a common objective in the field.
    • Expectation of Success: A POSITA would have had a high expectation of success, as adding capacitors to create resonant circuits was a fundamental and well-understood technique for improving ICPT systems.

Ground 3: Obviousness with Antenna Array & Switching - Claims 4-6 are obvious over Odachi, Wang, and Partovi.

  • Prior Art Relied Upon: Odachi (Patent 5,617,003), Wang (a 2004 Ph.D. dissertation), and Partovi (Patent 7,952,322).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Odachi and Wang. Partovi was cited for its teaching of using an "array of antennas" for the transmitter that extends over a larger area, rather than a single coil. Partovi further disclosed selectively activating the specific coil in the array that is best aligned with the receiver using a switch. This combination allegedly met the limitations of claim 4 (antenna array), claim 5 (selecting an antenna), and claim 6 (switching device).
    • Motivation to Combine: A POSITA would be motivated to replace Odachi's single-coil transmitter with Partovi's antenna array to expand the permissible parking area for a vehicle. This would make the charging system more user-friendly by accommodating less precise parking, furthering Odachi's goal of reducing "laborious parking operations." Selectively activating the best-coupled coil would also predictably improve energy efficiency.
    • Expectation of Success: The expectation of success was high, as using coil arrays and selective activation were known techniques in the wireless charging art.

Ground 4: Obviousness with Movable Receiver System - Claims 8-10, 12-14, 16, and 19 are obvious over Ross in view of Wang.

  • Prior Art Relied Upon: Ross (Patent 5,669,470) and Wang (a 2004 Ph.D. dissertation).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Ross disclosed a roadway-powered electric vehicle system with a stationary transmitting coil embedded in the road. In Ross, the vehicle is first guided into a "rough tolerance" alignment position. A fine alignment is then performed by physically moving the vehicle's receiving antenna laterally and vertically to maximize coupling. Ross taught that coupling is sensed by "monitoring the change in the amplitude of the inductively received power signal." Wang, as in other grounds, supplied the reason to make Ross's coils resonant by adding capacitors.
    • Motivation to Combine: A POSITA would combine Wang’s teachings with Ross’s system for the same reason as in the Odachi combination: to improve power transfer efficiency. This was a known benefit for a high-power application and would yield a predictable improvement.
    • Expectation of Success: Success would be expected, as the modification involved applying a well-known technique (resonant compensation) to a known system to achieve a predictable result.

4. Arguments Regarding Discretionary Denial

  • §325(d): Petitioner argued that denial under §325(d) was unwarranted because the primary prior art references—Odachi, Wang, and Ross—were not considered during the original prosecution. Petitioner contended that while the Examiner considered a different patent by the same inventor as Ross ([Ross-090](https://ai-lab.exparte.com/case/ptab/IPR2024-00140/doc/1011)), the Examiner made material errors in that analysis and that the arguments and evidence presented in the petition are substantially new and different.
  • Fintiv: Petitioner asserted that discretionary denial under Fintiv was inappropriate because the parallel district court litigation was in its earliest stages, with no scheduling order entered or trial date set.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 4-10, 12-16, and 18-19 of the ’654 patent as unpatentable.