PTAB

IPR2024-01219

Deltran USA LLC v. NOCO Co

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1. Case Identification

2. Patent Overview

  • Title: Portable Vehicle Battery Jump Start Apparatus with Safety Protection
  • Brief Description: The ’203 patent discloses a portable vehicle jump starter apparatus. The device includes an internal rechargeable power supply, safety sensors to detect battery presence and correct polarity before connecting power, a USB port for charging the internal power supply, and a DC-DC converter configured to "boost" or increase the voltage received from the USB port to charge the higher-voltage internal batteries.

3. Grounds for Unpatentability

Ground 1: Obviousness over Richardson and Zhao - Claims 1, 3-5, and 9 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 that Richardson taught a portable jump starter with nearly all the claimed safety features, including separate sensors for detecting vehicle battery presence (vehicle voltage sensor 30) and reverse polarity (reverse voltage sensor 24) that control a power switch (contact relay 34). Petitioner noted that these features in Richardson were previously found by the Board to anticipate the claims of a parent patent. Zhao was asserted to teach the primary missing element: a battery charging system that uses a standard 5V USB input and a DC-DC "step-up" converter to increase the voltage to charge a higher-voltage, multi-cell battery pack.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Zhao’s ubiquitous USB charging circuit with Richardson’s jump starter to provide a convenient, alternative method for charging the device. This modification would increase the product’s flexibility, allowing a user to charge it from widely available USB power sources when a vehicle battery is unavailable, achieving the predictable result of a more versatile jump starter.
    • Expectation of Success: A POSITA would have a high expectation of success. The petition asserted that combining a standardized USB charging circuit with a battery-powered device was a well-known and routine design choice. Zhao provided sufficient technical detail to implement its charging circuit, and the patent’s own inventors had requested a similar device be manufactured prior to the patent’s filing date, suggesting they believed it was readily achievable.

Ground 2: Obviousness over Yu and Paparrizos - Claims 1, 3-5, and 9 are obvious over Yu in view of Paparrizos.

  • Prior Art Relied Upon: Yu (Chinese Utility Model Patent No. CN 203211234) and Paparrizos (Patent 9,219,372).

  • Core Argument for this Ground:

    • Prior Art Mapping: As an alternative to the Richardson combination, Petitioner argued that Yu taught a jump starter with the core claimed elements, including an internal battery, a power switch (relay 2), an external battery voltage detection circuit (for presence), and a separate external battery reverse connection detection circuit. Paparrizos was alleged to teach a battery charging circuit with a "forward boost mode" that uses a DC-DC converter to boost a 5V USB input to a sufficient voltage to charge higher-voltage batteries, including 12V multi-cell lithium-ion packs suitable for a jump starter.
    • Motivation to Combine: A POSITA would be motivated to modify Yu's jump starter to incorporate the popular and convenient USB charging feature from Paparrizos. This would add a widely adopted charging method to Yu's device, allowing it to be charged via a 5V USB input in addition to its existing 12V input, thereby enhancing its marketability and utility.
    • Expectation of Success: Success would be expected and the results predictable, as Paparrizos employed well-known concepts of using a DC-DC boost converter with a standard 5V USB input. Implementing this known charging circuit into the battery-charging portion of Yu's jump starter would be a straightforward integration for a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for the dependent claims.

    • Claims 2, 10, and 11 were argued to be obvious over the primary combinations (Richardson/Zhao or Yu/Paparrizos) in further view of Epower-20/Epower-21 (product brochures) or Applicant Admitted Prior Art (AAPA). These references were cited to teach making the jump starter a "hand-held device" (claim 2) and adding a USB output port for charging external devices (claims 10 and 11).
    • Claims 6-8 were argued to be obvious over the primary combinations in further view of Krieger (Application # 2004/0130298). Krieger was cited to teach using a FET switch as the power switch (claim 6) and using an "optically coupled isolator phototransistor" for the vehicle isolation and reverse polarity sensors (claims 7 and 8), which Petitioner argued was a known and desirable design improvement.

4. Arguments Regarding Discretionary Denial

  • §325(d) (Same Art/Arguments): Petitioner argued against discretionary denial under §325(d), asserting that its grounds relied on new prior art not previously considered by the Examiner. Specifically, Petitioner contended that Zhao and Paparrizos teach the exact limitation—a DC-DC boost converter for USB charging—that the Examiner mistakenly believed was novel and formed the basis for allowance. Petitioner argued this constituted a material error by the Patent Office, as the Examiner failed to locate or appreciate the most relevant art.
  • §314(a) (Parallel Litigation): Petitioner argued against discretionary denial under §314(a) by noting it had filed a stipulation in the parallel district court litigation. Per the USPTO's guidance, this stipulation, in which Petitioner agreed not to pursue in district court any ground raised or that could have reasonably been raised in the IPR, weighs strongly against denial.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-11 of the ’203 patent as unpatentable.