PTAB

IPR2024-00230

Microchip Technology Inc v. Aptiv Technologies AG

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Flexible Mobile Device Connectivity to Automotive Systems with USB Hubs
  • Brief Description: The ’072 patent discloses a system for connecting a dual-role USB product, such as a smartphone, to an upstream host, like a vehicle's embedded infotainment system. The system modifies a traditional USB hub by adding a host-to-host bridge and routing switches to allow the downstream product to operate in either a host mode (byrouting signals through the bridge) or a device mode (by bypassing the bridge).

3. Grounds for Unpatentability

Ground 1: Obviousness over Chang and Chang II - Claim 1 is obvious over Chang in view of Chang II and the knowledge of a POSITA.

  • 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 discloses the core components of a USB hub with a connected host-to-host bridge, providing separate transmission paths for host-to-host and host-to-device communications via dedicated downstream ports. However, Chang lacks a dual-role port and the switching logic to automatically route signals based on a connected device's mode. Chang II was asserted to cure this deficiency by teaching a data transmission bridge with a single interface for connecting either a host or a device. Chang II's system includes a detection unit to determine the connected product's role and logic to switch between a bridge path (for host-to-host communication) and a bypass path (for host-to-device communication).
    • Motivation to Combine: A POSITA would combine these teachings to improve upon Chang's design. The use of dedicated ports in Chang was described as costly and inconvenient for users with dual-role devices like smartphones, especially in a vehicle context. Petitioner asserted a POSITA would be motivated to replace Chang's separate host and device ports with the single, dual-role port and automatic switching functionality from Chang II to reduce hardware complexity, lower costs, and create a more user-friendly, seamless connection experience. This combination was presented as a predictable design choice to adapt a known hub architecture to the well-established trend of dual-role consumer electronics.
    • Expectation of Success: A POSITA would have had a high expectation of success because dual-role ports, mode-detection circuitry, and multiplexing switches were all well-known, commercially available components with understood signaling protocols at the time of the invention.

Ground 2: Obviousness over Chang, Chang II, and Chutorash - Claim 1 is obvious over Chang in view of Chang II, Chutorash, and the knowledge of a POSITA.

  • Prior Art Relied Upon: Chang (Application # 2006/0206650), Chang II (Application # 2009/0268743), and Chutorash (Patent 8,447,598).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1 by adding Chutorash to explicitly place the combined hub system into the claimed automotive environment. Petitioner argued that Chutorash discloses a vehicle control system, which it describes as an "embedded host," that uses USB interfaces to connect to numerous portable devices. The analysis of how Chang and Chang II teach the hub, bridge, dual-role port, and switching functionality remains the same as in Ground 1.
    • Motivation to Combine: The motivation to add Chutorash was to apply the improved hub from the Ground 1 combination to its intended and obvious environment. Chutorash established the known practice of using USB connectivity in vehicle infotainment systems. Given that the ’072 patent is directed to automotive systems and that connecting smartphones to cars was a known need, Petitioner contended it would have been obvious for a POSITA to implement the more advanced, dual-role hub of Chang and Chang II within the vehicle system described by Chutorash. This addressed the specific need for connecting dual-role smartphones, which can act as hosts, to an embedded vehicle host.
    • Expectation of Success: Success was asserted to be highly predictable, as this ground merely involves implementing a known type of improved USB hub (from Chang and Chang II) within a well-known application environment for USB hubs (Chutorash's vehicle system).

4. Key Claim Construction Positions

  • "Embedded USB Host": Petitioner proposed that this term be construed to mean "USB host physically embedded in a vehicle." This construction was based on a stipulation in a related district court case and supported by the ’072 patent specification, which describes the host function being embedded into a component of a vehicle infotainment system, such as a radio or head unit. This construction is central to Ground 2, which relies on Chutorash to teach the vehicle environment.

5. Arguments Regarding Discretionary Denial

  • §314(a) (Fintiv): Petitioner argued against discretionary denial under Fintiv by stipulating that if the Board institutes this inter partes review (IPR), Petitioner will not pursue invalidity of the challenged claim in a parallel district court proceeding on the same grounds or any grounds that could have reasonably been raised in the petition.
  • §325(d): Petitioner contended that denial would be inappropriate because the core prior art and arguments were not before the examiner during prosecution. Notably, Chang II was never cited or considered during the prosecution of the ’072 patent. Therefore, the examiner did not have the opportunity to evaluate the key combination of Chang's bridge-equipped hub with Chang II's dual-role port and automatic switching logic, which forms the basis of the petition's obviousness grounds.

6. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claim 1 of the ’072 patent as unpatentable.