PTAB

IPR2024-00995

Anker Innovations Ltd v. Powermat Technologies Ltd

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1. Case Identification

2. Patent Overview

  • Title: TRANSMISSION-GUARD SYSTEM AND METHOD FOR AN INDUCTIVE POWER SUPPLY
  • Brief Description: The ’204 patent relates to inductive power transmission systems. The technology focuses on controlling power transfer by operating a driver at a non-resonant transmission frequency that is "substantially different" from the inductive couple's characteristic resonant frequency, which is adjusted in response to feedback signals to regulate power delivery.

3. Grounds for Unpatentability

Ground 1A: Anticipation of Claims 1-6, 8, and 10-13 by Onishi

  • Prior Art Relied Upon: Onishi (Application # 2008/0197804).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Onishi disclosed every limitation of the challenged claims. Onishi teaches an inductive power system that operates at non-resonant frequencies (e.g., f1, f3) that are substantially different from its characteristic resonant peak (f0). The system’s control and waveform detection circuits function as the claimed "signal detector," which is adapted to detect a "first signal" (a "save command" indicating charging is complete) and a "second signal" (a change to a "high-load state" indicating charging should resume). Petitioner asserted that upon detecting the first signal, Onishi's driver provides less power by incrementally increasing the transmission frequency (e.g., from f1 to f3 for power-saving mode). Conversely, upon detecting the second signal, the driver provides more power by decreasing the frequency (e.g., from f3 to f1 for normal transmission mode), directly mapping to the method and system claims.

Ground 1B: Obviousness of Claims 1-6, 8, and 10-13 over Onishi in view of Purdy

  • Prior Art Relied Upon: Onishi (Application # 2008/0197804) and Purdy (Application # 2007/0236169).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to anticipation. Petitioner argued Onishi provided the foundational inductive charging system operating at non-resonant frequencies. Purdy, which relates to battery charging systems, was argued to supply the teaching of using feedback signals that carry specific operational parameters of the electric load, as recited in dependent claims 3 and 4. Purdy explicitly discloses transmitting parameters such as required operating voltage, required operating current, and battery charge level.
    • Motivation to Combine: A POSITA would combine Purdy's detailed feedback signaling with Onishi's power control system to achieve the well-known goals of improving charging safety, speed, and efficiency. This combination would allow the charger to accurately tailor power delivery based on the specific needs and status of the battery, thereby preventing damage and optimizing performance.
    • Expectation of Success: Petitioner asserted a high expectation of success, as both references address inductive charging systems and the use of feedback for control, making the integration of Purdy's more specific feedback data into Onishi's control loop a predictable and straightforward design choice.

Ground 2: Obviousness of Claims 1-6, 8, and 10-13 over Baarman392 in view of Tocci

  • Prior Art Relied Upon: Baarman392 (Application # 2008/0079392) and Tocci (a 2007 textbook on digital systems).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Baarman392 disclosed an inductive charging system that adjusts its non-resonant operating frequency based on binary feedback indicating either a normal or an abnormal (e.g., over-voltage or over-current) charging condition. Tocci, a conventional textbook, taught the fundamental concept of expressing such binary conditions using Boolean logic variables (e.g., HIGH/LOW signals). In the proposed combination, the abnormal charging condition in Baarman392 would be represented by a "first signal" (e.g., a HIGH logic level), and the normal condition would be represented by a "second signal" (e.g., a LOW logic level). Baarman392’s controller would then adjust the frequency—increasing it to provide less power upon detecting the first signal, and decreasing it to provide more power upon detecting the second signal.
    • Motivation to Combine: A POSITA would have been motivated to implement the binary feedback system of Baarman392 using the standard Boolean logic taught by Tocci. This was a conventional, well-established technique for designing digital logic circuits that would simplify implementation, reduce noise, and align the system with traditional digital design practices.
    • Expectation of Success: The combination involved applying fundamental, textbook-level digital design principles to a known system architecture, making the outcome highly predictable and ensuring a reasonable expectation of success.

4. Key Claim Construction Positions

  • Petitioner argued that the claim term "substantially different", referring to the transmission frequency, was a key point of novelty asserted during prosecution. Based on the file history and specification, Petitioner contended the term should be construed to mean a frequency selected to lie within the "near-linear regions" of the system's frequency-amplitude graph. This construction is critical to the invalidity arguments, as both Onishi and Baarman392 allegedly disclose operating their systems in these exact off-resonance regions for stable power control.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. Against denial under 35 U.S.C. §325(d), Petitioner asserted that the primary references (Onishi, Purdy, Baarman392, and Tocci) were never presented to or considered by the Examiner during prosecution. Against discretionary denial under Fintiv, Petitioner noted it had filed a Sotera stipulation, eliminating any risk of duplicative efforts or inconsistent rulings by agreeing not to pursue in a parallel district court proceeding the same grounds, or any grounds that could have been reasonably raised in the IPR.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6, 8, and 10-13 of the ’204 patent as unpatentable.