PTAB

IPR2024-01478

Dell Inc v. Universal Connectivity Technologies Inc

Key Events

Petition

petition

Title: Power Delivery Over Digital Interaction Interface for Video and Audio
Brief Description: The ’712 patent discloses a power delivery circuit for devices connected in a network, such as a serial daisy chain. The circuit is configured to detect a connected device's load to extract information about its power status (e.g., powered on/off) and power needs, and subsequently control the delivery of power to that device.

Prior Art Relied Upon: Biederman (Application # 2006/0089230) and IEEE 802.3af (a 2003 industry standard for Power over Ethernet).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Biederman discloses a bidirectional Power over Ethernet (PoE) system with devices connected in a daisy chain, including a power source, a controller, and relay switches. However, Biederman omits routine implementation details for PoE device detection. Petitioner asserted that the well-known IEEE 802.3af standard supplies these details, teaching the use of a load detector in power sourcing equipment (PSE) to read a specific signature resistance in a powered device (PD). This process allows the PSE to extract information about whether the PD requires power and its power classification.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the standard PoE features from IEEE 802.3af with Biederman’s system because Biederman explicitly states its technology is a PoE system governed by that very standard. Biederman further notes that implementing such routine features would be a predictable engineering task, providing a direct motivation for the combination.
- Expectation of Success: A POSITA would have had a reasonable expectation of success, as incorporating the specific, well-defined protocols of the IEEE 802.3af standard into a general PoE framework like Biederman's was a common and routine engineering practice.

Prior Art Relied Upon: Biederman (Application # 2006/0089230) and Karam (Application # 2006/0100799).
Core Argument for this Ground:
- Prior Art Mapping: As an alternative to relying on the IEEE standard, Petitioner argued that Karam provides a concrete example of the routine PoE features omitted by Biederman. Karam explicitly teaches a daisy-chained PoE system where a PSE uses a discovery process to detect an "identity network" (a 25,000Ω signature resistor) in a PD. This detection, performed by a current sensor (load detector), is used to extract information regarding the PD's power needs and status before power is relayed.
- Motivation to Combine: A POSITA would combine Karam’s specific implementation of PoE detection and classification with Biederman's broader daisy-chain power system. Biederman’s admission that it omits routine features would have motivated a POSITA to look to other art, like Karam, which addresses the same PoE field and provides a detailed solution for the exact functions required for Biederman's system to operate as intended.
- Expectation of Success: The combination was expected to be successful because Karam provides a functional, detailed implementation of the same standard PoE detection and classification features that Biederman’s system would fundamentally require.

Prior Art Relied Upon: Karam (Application # 2006/0100799).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Karam discloses every limitation of method claims 7 and 9. Karam teaches a method for delivering power to daisy-chained devices by first performing a discovery process to detect a load (the signature resistance) in a first device. This process includes detecting a load current to verify the device can receive power. Karam further teaches extracting information based on this detection (e.g., power class) and then relaying power based on the extracted information. For claim 9, Karam’s control circuitry is taught to detect the removal of a device by sensing when the current draw from a port drops to zero, thereby meeting the "detecting removal" limitation.
Additional Grounds: Petitioner asserted additional obviousness challenges (Grounds 3-5 of the petition) based on combinations of Biederman, IEEE 802.3af, Karam, and Penning (Application # 2008/0168283). These grounds argued that Penning provides further teachings on using power detectors to switch between a main power source and a local backup supply, addressing claim limitations related to detecting a power source.

Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is unwarranted. The petition asserted that several key prior art references—Biederman, IEEE 802.3af, and Penning—were never considered by the USPTO examiner during the original prosecution. Additionally, while the examiner cited Karam, it was only as a secondary reference, and the examiner failed to appreciate that Karam disclosed the very limitations that were added to the claims to secure their allowance.

Petitioner requests the institution of an inter partes review and the cancellation of claims 1-3, 5, 7, and 9 of the ’712 patent as unpatentable.