PTAB

IPR2024-00671

ADC Solutions Auto LLC v. NOCO Co

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Jump Starting Device with USB
  • Brief Description: The ’243 patent relates to a portable jump starting device for vehicle batteries. The challenged claims add standard USB input technology for charging the device's internal battery and USB output technology for charging external electronic devices.

3. Grounds for Unpatentability

Ground 1: Obviousness of Core Jump Starter with USB Charging - Claims 1 and 2 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 argued Richardson taught all elements of a conventional jump starter as recited in independent claim 1, including a power supply, positive and negative battery connectors, and a power switch. For claim 2, Petitioner asserted that Richardson's microprocessor-controlled system, which includes a "reverse voltage sensor," was configured to close its power switch (a relay) only when connected with the correct polarity to a vehicle battery. Petitioner contended Zhao supplied the missing elements of claim 1 related to USB charging: a USB input connector and a USB charge circuit comprising a DC-DC converter configured to upconvert, or boost, a 5V input from a USB source to charge a higher-voltage multicell battery pack.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Richardson’s jump starter with Zhao’s USB charging system to achieve the predictable result of providing a convenient and flexible alternative charging method. This modification would cater to established consumer demand for the universal and ubiquitous nature of USB charging for portable electronic devices.
    • Expectation of Success: A POSITA would have had a high expectation of success because Zhao taught the known and established technique of using a DC-DC booster converter to charge a multicell battery pack (the same architecture in Richardson) from a standard 5V USB source.

Ground 2: Obviousness of Additional USB Output and Battery Features - Claims 15, 17, 18, 51, 54, and 57 are obvious over Richardson in view of Zhao and Dao.

  • Prior Art Relied Upon: Richardson (Application # 2013/0154543), Zhao (Patent 9,391,467), and Dao (Application # 2013/0241488).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1, with Petitioner asserting that Dao, another jump starter reference, taught the additional features recited in the challenged dependent claims and independent claim 57. Petitioner argued Dao disclosed a USB output connector for charging external devices (claims 15 and 57(h)-(i)), a microcontroller to control the USB output circuit to prevent over-discharge (claim 18), the use of a rechargeable lithium battery pack as the power supply (claim 51), and a voltage measurement circuit for overcharge and overdischarge protection (claim 54).
    • Motivation to Combine: A POSITA would add Dao’s features to the Richardson/Zhao combination to enhance the device’s functionality and safety. Adding a USB output was a known practice to allow the jump starter to double as a power bank, and implementing lithium batteries with corresponding protection circuitry was a known method to create a more compact, powerful, and safer device.

Ground 3: Obviousness via an Alternative Primary Combination - Claims 1, 2, 15, 17, 18, and 57 are obvious over Yu in view of Paparrizos.

  • Prior Art Relied Upon: Yu (Chinese Utility Model Patent CN 202311234 U) and Paparrizos (Patent 9,219,372).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yu, an automotive starting device, disclosed a base jump starter with all the core features of claims 1 and 2, including a power supply, connectors, a microprocessor-controlled relay, and a reverse polarity detection circuit. Petitioner further argued Yu taught the USB output features of claims 15, 17, and 18. To supply the missing USB input charging limitations of claims 1 and 57, Petitioner relied on Paparrizos, which taught a battery charging circuit that boosts a lower input voltage (e.g., 5V from a USB source) to charge higher-voltage, multicell battery packs like the 12V battery in Yu.
    • Motivation to Combine: A POSITA would have been motivated to modify Yu's jump starter with the "very popular" USB charging technology from Paparrizos to predictably charge Yu's 12V battery. This would satisfy consumer demand for standard charging interfaces on portable devices.
    • Expectation of Success: Success was predictable because Paparrizos taught the conventional application of a DC-DC boosting technique for charging a higher-voltage battery from a standard 5V USB source, an established and well-understood engineering practice.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Yu in view of Paparrizos and Dao but relied on similar design modification theories.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §325(d), contending that the primary prior art combinations relied upon were not substantively considered during prosecution. Petitioner asserted that Zhao and Paparrizos were never before the Examiner and teach the exact DC-DC boosting feature that the Patent Owner successfully argued was missing from the art to overcome prior rejections.
  • Petitioner also argued against discretionary denial under §314(a) based on parallel litigation. It stated that under the USPTO's Guidance Memo, the parallel proceedings do not warrant denial and that Petitioner has offered a stipulation not to pursue in district court any grounds raised or that could have been reasonably raised in the IPR.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 15, 17, 18, 51, 54, and 57 of the ’243 patent as unpatentable.