PTAB

IPR2024-00156

Xu PeiCheng Hong Kong Optoelectronic Technology Co Ltd v. Semisilicon Technology Corp

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petition

1. Case Identification

2. Patent Overview

  • Title: Driving Apparatus for Light-Emitting Diode Curtain Lamp
  • Brief Description: The ’546 patent discloses a driving apparatus for a light-emitting diode (LED) light string, such as a curtain lamp. The apparatus consists of a master control unit that controls one or more slave control units to drive the LED strings, and can be powered by either a direct current (DC) or alternating current (AC) source.

3. Grounds for Unpatentability

Ground 1: Claims 1-2 are obvious over Kuang in view of the general knowledge of a POSITA.

  • Prior Art Relied Upon: Kuang (Application # 2009/0021955).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kuang discloses a complete lighting control network that meets all limitations of claim 1. Kuang’s “master node” is the claimed master control unit, which includes a microcontroller and a voltage regulator. Its “slave/LED nodes” are the slave control units, and the LEDs they control constitute the light string. Power is supplied by an on-board battery, which is a DC source. The master and slave nodes are connected by a “power/data bus,” which serves as the claimed transmission line to transmit control and synchronous signals. For dependent claim 2, Petitioner asserted that Kuang’s slave node includes components like a voltage boost regulator or a microcontroller that would be recognized by a person of ordinary skill in the art (POSITA) as a “signal processor.”
    • Motivation to Combine: As a single-reference ground, the motivation was inherent in Kuang’s integrated disclosure.
    • Expectation of Success: A POSITA would have expected Kuang’s disclosed system to function as described, as it uses conventional electronic components in a predictable manner.

Ground 2: Claims 1-2 and 8 are obvious over Lys in view of the general knowledge of a POSITA.

  • Prior Art Relied Upon: Lys (Patent 6,774,584).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Lys teaches a networked lighting system analogous to the claimed invention. Lys’s “remote or local user interface” functions as the master control unit, and its “controllers” function as the slave control units. The user interface contains a “processor” (microcontroller) and “selectors” that a POSITA would understand could function as a voltage regulator. The system is powered by a DC source and uses a data network as the transmission line. For claim 2, Petitioner argued that the microprocessor within Lys’s controller satisfies the “signal processor” limitation. For claim 8, which involves both AC and DC power, Petitioner asserted Lys discloses that its system can be powered by either an AC or DC source and explicitly mentions using an AC-to-DC converter, which is the claimed “alternating current voltage transferring to direct current voltage circuit.”
    • Motivation to Combine: This is a single-reference ground where all elements were argued to be present or rendered obvious by Lys's disclosure.
    • Expectation of Success: The components in Lys’s system were described as standard and their operation predictable.

Ground 3: Claims 5-6 and 8 are obvious over Hiroyuki in view of Kuang.

  • Prior Art Relied Upon: Hiroyuki (JP Application # 2006-228529) and Kuang (Application # 2009/0021955).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Hiroyuki discloses the base system of claim 4: a driving apparatus with a master drive unit and slave drive units for LED strings, powered by an AC source. For claim 5, Hiroyuki discloses a “diode bridge” which is a bridge rectifier. However, Hiroyuki does not explicitly disclose a microcontroller. Petitioner asserted that Kuang supplies this missing element with its disclosure of a master node containing a microcontroller. For claim 6, Petitioner argued that Hiroyuki’s “surge absorber (varistor, ZNR)” in its protection circuit would be understood by a POSITA to be a Zener diode connected to the bridge rectifier. The arguments for claim 8 relied on Hiroyuki’s master/slave architecture and AC-to-DC conversion, combined with the microcontroller taught by Kuang.
    • Motivation to Combine: A POSITA would combine Kuang’s microcontroller with Hiroyuki’s lighting apparatus to add desirable, advanced features, such as dynamic flashing and supervisory control, which are explicitly discussed in Kuang.
    • Expectation of Success: Incorporating a well-known component like a microcontroller into a lighting circuit to add functionality was argued to be a routine and predictable design modification with a high expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claim 3 is obvious over Kuang in view of Debevec (Application # 2012/0050606) and over Lys in view of Debevec, arguing Debevec supplies the teaching of a transistor in the slave control unit. Claim 4 was also challenged as obvious over Hiroyuki and general knowledge.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate under both 35 U.S.C. §314(a) and §325(d).
  • Regarding §314(a) and the Fintiv factors, Petitioner stated it was unaware of any parallel judicial or administrative matters that would be affected by the institution of this IPR.
  • Regarding §325(d), Petitioner argued that while the reference Debevec was considered during prosecution, it was used only as a primary reference for an obviousness rejection. This petition uses Debevec only as a secondary reference in new combinations with Kuang and Lys, which were never before the examiner. Petitioner contended this presents the art and arguments in a substantially new light, making denial under §325(d) unwarranted.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 8 of the ’546 patent as unpatentable.