PTAB

IPR2024-01454

Ericsson Inc v. Procomm Intl Pte Ltd

Key Events

Petition

petition

Title: Systems and Methods for Venturi Fan-Assisted Cooling
Brief Description: The ’521 patent discloses systems and methods for cooling electronic components within a sealed enclosure. The technology uses a fan to create a "first airflow" across the convective openings of a heatsink, which generates a Venturi effect to draw a "second airflow" of heated air through the heatsink to dissipate heat.

Prior Art Relied Upon: Sterner (Patent 7,028,753).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Sterner discloses a cooling apparatus for an electronic device (e.g., a notebook computer) that meets all limitations of the challenged claims. Sterner's air duct (15) functions as the claimed "Venturi chamber," and its fan (100) and an adjacent barrier (232) form the "fan shroud." A heatpipe (250) coupled to a second duct (410) constitutes the "heatsink." Petitioner asserted that Sterner’s fan draws a first airflow through the air duct, creating a low-pressure region that induces a second, heated airflow from the heatsink into the Venturi chamber, thereby teaching the claimed cooling method. For dependent claims, Petitioner argued Sterner’s first inlet encircles the heatsink’s convective opening (claim 4) and that its ambient airflow is inherently cooler than the heated airflow (claim 5).
- Motivation to Combine (for §103 grounds): Petitioner contended that modifying Sterner to include a backup fan (claim 3) would have been obvious. A POSITA would be motivated to add redundancy to a critical component like a fan to prevent system failure from overheating, which was a well-known engineering practice for improving reliability.
- Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in implementing a standard backup fan system, as it was a common and predictable solution.

Prior Art Relied Upon: Aakalu (Patent 5,894,407).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued Aakalu, which was cited during prosecution, teaches a cooling system for an outdoor electronics enclosure that renders the claims obvious. The system includes a housing, heatsinks, fans, and a solar shield. Petitioner mapped the space formed by Aakalu's top solar shield (52) and top panel (26) to the claimed "Venturi chamber." In Aakalu’s forced convection mode, a first airflow is drawn through top ventilators (66), which moves across the convective openings of a front heatsink. This action creates a Venturi effect that enhances a second, heated airflow moving upward through the heatsink channels. Critically, Petitioner argued this arrangement meets the limitation added during prosecution, "wherein the first airflow does not flow into the one or more convective openings of the heatsink," a teaching they contend the Examiner overlooked.
- Motivation to Combine (for §103 grounds): This ground was presented as an obviousness challenge based on a single reference. All elements were argued to be present in Aakalu's disclosed system.
- Expectation of Success (for §103 grounds): The expectation of success was inherent in Aakalu's own disclosure of an operational cooling system.

Prior Art Relied Upon: Aakalu (Patent 5,894,407) and Jones (Patent 6,104,003).
Core Argument for this Ground:
- Prior Art Mapping: This ground used Aakalu as the primary reference for the base cooling system and combined it with Jones to supply features for dependent claims. Petitioner asserted that Jones discloses an electronics cabinet cooling system with advanced control features. Specifically, Jones teaches using one fan from a plurality as a redundant backup to provide the "backup fan" limitation of claim 3. Jones also explicitly teaches using a thermal controller to operate fans only when a sensed temperature exceeds a predetermined threshold, satisfying the limitations of method claims 18 and 19.
- Motivation to Combine (for §103 grounds): A POSITA would combine Jones's teachings with Aakalu’s system to enhance its reliability and efficiency. Jones provides an express motivation to use backup fans for redundancy in critical cooling systems. Further, a POSITA would be motivated to add Jones's temperature-based fan control to conserve power and reduce mechanical wear when forced convection is not needed, a common design goal for such systems.
- Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in integrating well-understood concepts like backup fans and thermal controllers, as taught by Jones, into the cooling system of Aakalu.

§325(d) - Same Art or Arguments: Petitioner argued against discretionary denial, asserting that while Aakalu was before the Examiner, the arguments presented in the petition were not. Petitioner contended the Examiner erred by failing to appreciate the full teachings of Aakalu, particularly how it discloses that the first airflow does not enter the heatsink openings. Petitioner also noted that Sterner, though listed in an IDS, was not substantively discussed or applied during prosecution and was therefore not materially considered by the Office.
§314(a) - Fintiv Factors: Petitioner argued that the Fintiv factors weigh against discretionary denial. It was asserted that the co-pending district court litigation is in its early stages with minimal investment. Furthermore, Petitioner stipulated that it would not pursue the same invalidity grounds in the district court if the IPR is instituted. Petitioner characterized the merits of the petition as particularly strong and compelling, further weighing in favor of institution.

Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 14-20 of Patent 7,724,521 as unpatentable.