Tesla Inc v. Charge Fusion Technologies LLC

1. Case Identification

• Case #: IPR2025-00152
• Patent #: 11,990,788
• Filed: November 8, 2024
• Petitioner(s): Tesla, Inc.
• Patent Owner(s): Charge Fusion Technologies LLC
• Challenged Claims: 1-17

2. Patent Overview

• Title: Electrical Charging System
• Brief Description: The ’788 patent discloses an electrical charging system for electric vehicles. The system uses a graphical user interface (GUI) to receive a user-defined desired charge level and displays a "unitary vehicle charge indicator" that combines the current charge level, the uncharged battery capacity, and a user-operable slider for setting the desired charge.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sutardja, Donnelly, and Letendre - Claims 1-4, 6-9, and 11-14 are obvious over Sutardja in view of Donnelly and Letendre.

• Prior Art Relied Upon: Sutardja (Application # 2008/0136371), Donnelly (Patent 7,124,691), and Letendre (a 2002 article in PUBLIC UTILITIES FORTNIGHTLY).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Sutardja taught the foundational electrical charging system, including a charge management module in a vehicle that receives user-defined charging parameters (like a desired charge level) and controls charging. To implement a user-friendly interface, Petitioner asserted a POSITA would have looked to Donnelly, which taught a touchscreen GUI for hybrid vehicles that displayed the battery's state of charge using a bar graph (mapping to the claimed "first portion" indicating charge and "second portion" indicating uncharged capacity). Petitioner further argued it would have been obvious to incorporate the slider taught by Letendre, which disclosed a vehicle dashboard control with a slider for setting a desired charge level based on travel distance (mapping to the claimed "third portion"). The combination of these elements on a single display was argued to create the claimed "unitary vehicle charge indicator."
  • Motivation to Combine: A POSITA would combine Sutardja's system with Donnelly's GUI because GUIs were the standard for human-computer interaction, offering a familiar and efficient way for users to input charging parameters. The motivation to add Letendre's slider was to apply a known, convenient technique for user input to an existing GUI, improving usability by allowing a user to easily select a charge level rather than entering a specific number. Displaying these elements together in a "unitary" fashion was motivated by the desire to improve display space utilization and provide all relevant information at a single glance.
  • Expectation of Success: Given the ubiquity of GUIs, bar graphs for status indication, and sliders for input in vehicle systems, a POSITA would have had a high expectation of success in combining these known elements to yield a predictable, more user-friendly charging interface.

Ground 2: Obviousness over Sutardja, Donnelly, Letendre, and Seelig - Claims 5, 10, and 15 are obvious over the combination of Ground 1 in view of Seelig.

• Prior Art Relied Upon: Sutardja (Application # 2008/0136371), Donnelly (Patent 7,124,691), Letendre (a 2002 article), and Seelig (Patent 5,654,621).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Sutardja, Donnelly, and Letendre from Ground 1. To meet the additional limitation of transmitting a control signal to a "parking space charge device" to initiate charging, Petitioner relied on Seelig. Seelig taught a contactless, inductive charging system where a primary transmitter element was located in a parking space. To start charging, the electric vehicle transmitted a wireless control signal to this stationary device.
  • Motivation to Combine: A POSITA would have been motivated to replace Sutardja's wired charging system with Seelig's known wireless charging technology to improve user convenience and reliability. Wireless charging was known to be simpler for the user (eliminating the need to plug in a cable) and reduced opportunities for human error, such as forgetting to plug the vehicle in. Seelig expressly noted the benefits of wireless charging, providing a clear motivation to incorporate its teachings into a modern EV charging system like Sutardja's.
  • Expectation of Success: Since wireless charging stations were well-known for decades prior to the patent's priority date, a POSITA would have had a reasonable expectation of success in integrating Seelig's wireless communication and charging components into the base system of Sutardja.

Ground 3: Obviousness over Sutardja, Donnelly, Letendre, and Knockeart - Claims 16-17 are obvious over the combination of Ground 1 in view of Knockeart.

• Prior Art Relied Upon: Sutardja (Application # 2008/0136371), Donnelly (Patent 7,124,691), Letendre (a 2002 article), and Knockeart (Patent 6,622,083).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground also built upon the base combination from Ground 1. To meet the limitations of the GUI forming part of a "mobile display device" (claim 16) and a "smartphone" (claim 17), Petitioner relied on Knockeart. Knockeart taught a system where a user's removable personal device, such as a cellular telephone or PDA, could be used to provide a vehicle's GUI.
  • Motivation to Combine: A POSITA would have been motivated to display the charging system's GUI on a mobile device, as taught by Knockeart, to provide the predictable result of allowing the user to enter charging parameters and check charging status when away from the vehicle. This added significant user convenience. Since PDAs and early smartphones were known to have touchscreen GUIs, implementing the combined Sutardja/Donnelly/Letendre interface on such a device was a natural and obvious design choice.
  • Expectation of Success: The modification would have been straightforward for a POSITA, simply requiring programming the system to display its GUI on a mobile device via a docked or wireless connection, which was within the ordinary skill in the art.

4. Key Claim Construction Positions

• "unitary vehicle charge indicator" (claims 1, 6, 11): Petitioner argued this term should be construed to at least include a bar graph that comprises the charged portion, uncharged portion, and the slider portion, as depicted in the patent's Figure 7.
• "(i) a first portion indicative of an amount of charge...; (ii) a second portion indicative of an uncharged capacity..." (claims 1, 6, 11): Petitioner contended these limitations were directed to "printed matter" and should be given no patentable weight. The argument was that these portions merely communicate information (the state of charge) and are not functionally related to the substrate (the GUI), as they do not interact with other claim elements to cause a specific action.

5. Arguments Regarding Discretionary Denial

• Discretion under §325(d): Petitioner argued that discretionary denial would be improper because none of the prior art references relied upon in the petition were cited or considered during the original prosecution of the ’788 patent. Therefore, the petition raised new arguments and art that were not before the Examiner.
• Discretion under §314(a) (Fintiv): Petitioner asserted that denial based on co-pending litigation would be inappropriate. While related litigation existed between the parties, the ’788 patent was not currently the subject of that litigation, and the litigation itself was stayed.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-17 of the ’788 patent as unpatentable.