PTAB

IPR2024-00577

ADC Solutions Auto LLC v. NOCO Co

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1. Case Identification

2. Patent Overview

  • Title: Portable Vehicle Battery Jump Start Apparatus with Safety Protection and Jumper Cable Device Thereof
  • Brief Description: The ’023 patent describes a portable jump starter for vehicle batteries that incorporates safety features such as reverse polarity detection. The central inventive concept asserted during prosecution was the addition of a USB input circuit, including a DC-DC converter, to allow the device's internal battery to be recharged from a standard 5V USB power source by boosting the input voltage to a level sufficient to charge the higher-voltage internal battery.

3. Grounds for Unpatentability

Ground 1: Obviousness over Richardson and Zhao - Claims 1, 32, 38, 39, 47, 52, and 54 are obvious over Richardson in view of Zhao.

  • Prior Art Relied Upon: Richardson (Application # 2013/0154543) and Zhao (Patent 9,391,467).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Richardson discloses a conventional portable jump starter with all the core features of the challenged claims, including a power supply, battery terminal connectors, and a microprocessor-controlled power switch with safety checks for correct polarity. Petitioner noted that in a prior inter partes review (IPR) on a parent patent, the Board found Richardson anticipated claims with these same features. The only element Petitioner contended is not taught by Richardson is the specific USB charging circuit that increases voltage. Zhao was argued to supply this missing element, as it explicitly teaches a battery charging system with a "step-up topology" (i.e., a DC-DC boost converter) for charging a multicell battery pack from a low-voltage 5V USB power source.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Richardson and Zhao to add the highly desirable and commercially valuable feature of standard USB charging to Richardson's jump starter. Zhao is directed to the same technical problem of charging multicell batteries—the same architecture used in Richardson's device. Adding a USB input would increase user convenience, reduce the need for proprietary chargers, and cater to consumer demand for universal charging solutions, which were well-established trends before the patent's priority date.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination. Implementing a DC-DC boost converter to step up a 5V USB input to charge a higher voltage battery (e.g., 12V) was a known, predictable, and widely documented application of standard electrical engineering principles and commercially available components.

Ground 2: Obviousness over Yu and Paparrizos - Claims 1, 32, 38, 39, 47, 52, and 54 are obvious over Yu in view of Paparrizos.

  • Prior Art Relied Upon: Yu (Chinese Utility Model Patent No. CN 202311234) and Paparrizos (Patent 9,219,372).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yu, like Richardson, discloses a conventional jump starter with the necessary core components, including an internal 12V battery, output terminals, and a microprocessor-controlled relay with safety circuits for detecting reverse polarity and battery presence. While Yu discloses a charging input, it is a non-USB, 12V/1A barrel-style receptacle. Paparrizos was asserted to teach the missing USB charging functionality. Paparrizos discloses a battery charging circuit that operates in a "forward boost mode" to step up a low input voltage from a USB source to charge multicell battery packs with higher voltages, specifically contemplating charging a 12V (3S) battery from a 5V USB input.
    • Motivation to Combine: A POSITA would be motivated to modify Yu's jump starter by replacing its barrel-style input with the USB boost-charging circuit taught by Paparrizos. This modification would achieve the predictable result of making the device rechargeable via ubiquitous USB power sources, a feature Paparrizos itself identifies as highly popular and desirable for consumers. The combination would enhance the product's utility and marketability by aligning it with universal charging standards.
    • Expectation of Success: A POSITA would have a high expectation of success. Paparrizos provides a detailed teaching of implementing a boost converter for this exact purpose and even refers to the "Basic Boost Converter Circuit" as known prior art. Integrating this known charging technique into another battery-powered device like Yu's jump starter would be a straightforward application of established technology.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §325(d), contending that the new prior art and arguments are not the same or substantially the same as what the Examiner considered. Specifically, the Examiner allowed the claims after the Patent Owner argued that the cited art taught "bucking" (decreasing) voltage from a USB source, not "boosting" (increasing) it. The newly presented references, Zhao and Paparrizos, directly teach this missing boosting feature, demonstrating a material error by the Examiner who failed to locate or appreciate such art.
  • Petitioner also argued against discretionary denial under §314(a) (Fintiv), stating that the parallel proceeding is an ITC action, to which the Fintiv factors do not apply per USPTO guidance. For the co-pending district court litigation, Petitioner noted it had offered a stipulation not to pursue the same IPR grounds in that venue if review is instituted.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 32, 38, 39, 47, 52, and 54 as unpatentable under 35 U.S.C. §103.