PTAB

IPR2024-00229

Microchip Technology Inc v. Aptiv Technologies AG

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petition

1. Case Identification

2. Patent Overview

  • Title: Flexible Mobile Device Connectivity to Automotive Systems with USB Hubs
  • Brief Description: The ’962 patent relates to a Universal Serial Bus (USB) hub module designed to connect a dual-role device (e.g., a smartphone) to an upstream host. The purported invention adds a routing switch and a host-to-host bridge to a conventional hub, allowing communications to be selectively routed either through the bridge for host-to-host connections or around the bridge for standard host-to-device connections.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chang in View of Chang II - Claims 1-10 and 14-17 are obvious over Chang in view of Chang II and POSITA knowledge.

  • Prior Art Relied Upon: Chang (Application # 2006/0206650) and Chang II (Application # 2009/0268743).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chang taught a USB hub with a bridge to facilitate host-to-host communications, but it used separate, dedicated downstream ports for hosts and devices. Chang II taught a data transmission bridge device with a single, dual-role port that could connect to either a host or a device. Chang II’s device included a detection unit to determine the connected product’s role and a switching mechanism to select either a "bridge transmission path" for host-to-host communication or a "bypass path" for host-to-device communication. Petitioner contended that combining Chang's hub-and-bridge architecture with Chang II's dual-role port and switching functionality rendered the independent claims obvious. Dependent claims were met by additional disclosures in the combination, such as the use of a crossbar switch to enable simultaneous host and device connections (claim 2) and the inherent need for mode detection to control the switch (claim 3).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to address the growing popularity of dual-role consumer products like smartphones. Modifying Chang's architecture with Chang II's teachings would replace inconvenient and costly dedicated ports with a single, flexible port. This modification would improve user convenience, reduce the hub's cost and footprint, and directly align with Chang's stated goal of easily connecting computers (including smartphones acting as hosts).
    • Expectation of Success: A POSITA would have a high expectation of success because implementing dual-role ports and host/device detection involved well-known techniques and commercially available components. Chang II explicitly stated its relevance to USB hubs and provided a clear roadmap for switching between a bridge path and a bypass path based on the detected device mode.

Ground 2: Obviousness over Chang, Chang II, and AN96527 - Claims 11-13 and 18-19 are obvious over Chang in view of Chang II, AN96527, and POSITA knowledge.

  • Prior Art Relied Upon: Chang, Chang II, and AN96527 (a Cypress Semiconductor application note titled "Designing USB Type-C Products Using Cypress’s CCG1 Controllers").
  • Core Argument for this Ground: This ground asserted that adding the teachings of AN96527 to the combination of Chang and Chang II rendered obvious the claims directed to USB power delivery. The challenged claims (11-13 and 18-19) correspond to new matter added to the application that became the ’962 patent.
    • Prior Art Mapping: AN96527 described implementing the USB Power Delivery (USB-PD) standard in products including hubs. Petitioner argued AN96527 disclosed a "logic circuit" (the CCG1 controller) configured for "data handshaking to negotiate electrical power transfer," a "power supply circuit" to provide the negotiated power, a "communication control stack" (inherent in the USB-PD firmware), and "adjustable voltage power supplies." These disclosures directly mapped to the limitations recited in claims 11, 12, and 13.
    • Motivation to Combine: A POSITA would be motivated to incorporate the teachings of AN96527 into the hub of Ground 1 to provide enhanced and more convenient charging capabilities. The USB-PD standard, as explained in AN96527, enabled higher power delivery (up to 100W) and variable voltage levels, eliminating the need for separate wall chargers for devices like tablets and laptops. This was a known and desirable feature for consumer electronics.
    • Expectation of Success: AN96527 was an application note providing working reference designs, full schematics, and software details. It explicitly taught its applicability to USB hubs, which would have given a POSITA a very high expectation of successfully integrating its power delivery features into the hub design from Ground 1.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) is not warranted, stipulating that if the IPR is instituted, it will not pursue the same invalidity grounds, or any grounds that could have reasonably been raised, in parallel district court litigation.
  • Petitioner further argued that denial under 35 U.S.C. §325(d) is inappropriate because the primary prior art references, Chang and Chang II, were not submitted to or cited by the Examiner during the prosecution of the ’962 patent. Petitioner contended the references are not cumulative to the art of record and that the Examiner never considered the core argument of modifying a hub-with-bridge architecture to include a switched, dual-role port.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of U.S. Patent No. 9,645,962 as unpatentable.