Amphenol Corp v. Credo Technology Group Ltd

1. Case Identification

• Case #: IPR2025-00607
• Patent #: 11,495,898
• Filed: April 1, 2025
• Petitioner(s): Amphenol Corp.
• Patent Owner(s): Credo Technology Group Ltd.
• Challenged Claims: 1-20

2. Patent Overview

• Title: Connector Paddle Card with Staggered Signal Wire Solder Contacts
• Brief Description: The ’898 patent relates to printed circuit boards (PCBs), known as "paddle cards," used for terminating shielded signal wires in high-speed data cables. The purported invention involves arranging solder contacts in staggered inner and outer rows and providing a recess in the PCB to accommodate the sheathing of the outer wires, allegedly to reduce impedance mismatch.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Ayzenberg - Claims 1-2, 9-10, 16, and 18 are anticipated by or obvious over Ayzenberg.

• Prior Art Relied Upon: Ayzenberg (Application # 2020/0194911).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Ayzenberg, which discloses high-performance cable terminations, teaches every limitation of the challenged independent claims. Ayzenberg’s paddle card is a PCB with "contact pads 406" arranged along a first edge, corresponding to the claimed "edge connector traces." The PCB also includes two parallel rows of "solder pads 410" (rows 422A and 422B) for attaching signal wires, which Petitioner mapped to the claimed "outer set" and "inner set" of electrodes. Petitioner asserted that Ayzenberg’s figures demonstrate that the signal solder pad pairs in the inner row are staggered relative to those in the outer row, meeting the key limitation of claim 1. For dependent claim 2, Petitioner argued Ayzenberg’s staggered arrangement inherently spaces the electrodes to allow inner wires to pass between outer wires.
  • Motivation to Combine: Not applicable for anticipation. For obviousness, Petitioner asserted that a disclosure that anticipates under 35 U.S.C. §102 also renders a claim obvious under 35 U.S.C. §103.

Ground 2: Obviousness over Ayzenberg in view of Lugthart - Claims 3, 11, and 17 are obvious over Ayzenberg in view of Lugthart.

• Prior Art Relied Upon: Ayzenberg (Application # 2020/0194911) and Lugthart (Patent 9,882,706).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses claims requiring an integrated circuit (IC) that recovers and remodulates signals. Ayzenberg discloses that its paddle card can include "active components" such as "transceivers" in a designated space on the PCB but does not detail their specifics. Lugthart teaches a high-speed active cable with a transceiver IC at each end that performs clock and data recovery (CDR) and remodulates signals (e.g., converting between NRZ and PAM4 signal formats) to improve signal fidelity. Petitioner argued the combination places Lugthart’s specific transceiver IC onto Ayzenberg’s PCB, thereby providing the claimed IC that "recovers and remodulates signals" passing between the edge connector traces and the electrodes.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine these references to implement the generic "active components" suggested by Ayzenberg with the specific, performance-enhancing transceiver taught by Lugthart. The motivation would be to achieve the "high performance cable" described by Ayzenberg by using Lugthart's known techniques for improving signal integrity, reducing jitter, and permitting communication over longer distances.
  • Expectation of Success: A POSA would have an expectation of success because Ayzenberg explicitly provides space for such active components, and both references describe using PCBs in standard-compliant connectors. Combining these known elements for their intended and conventional purposes would yield the predictable result of an active cable with improved performance.

Ground 3: Obviousness over Ayzenberg in view of Janssen - Claims 4-8, 12-15, and 19-20 are obvious over Ayzenberg in view of Janssen.

• Prior Art Relied Upon: Ayzenberg (Application # 2020/0194911) and Janssen (Patent 9,887,496).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses claims requiring a recess in the PCB to accommodate the wire sheath. Petitioner argued Ayzenberg’s design, which places sheathed cables on the PCB surface, necessitates bending the exposed signal wires to connect them to the solder pads. Janssen addresses the problem of connecting shielded wires to a PCB by teaching a "ground contact zone" that forms a recess. This recess accommodates the wire’s sheathing, allowing the exposed conductor to lie flat and connect to a pad without bending. Petitioner contended that modifying Ayzenberg's PCB with Janssen’s recess would result in a PCB where the recess accommodates the outer wire sheath, enabling the exposed ends to contact the electrodes while remaining parallel to the surface, as claimed.
  • Motivation to Combine: A POSA would be motivated to incorporate Janssen's recess design into Ayzenberg's paddle card to solve the well-known problem of signal degradation caused by wire bends. Bends introduce impedance mismatches and "destructive resonances" that harm signal quality. Applying Janssen’s known solution to Ayzenberg’s design would be a straightforward way to improve signal integrity and simplify manufacturing and assembly.
  • Expectation of Success: Success would be reasonably expected because both references concern connecting shielded wires to PCBs for high-speed data applications (e.g., QSFP connectors). Applying Janssen's mechanical solution for managing wire sheathing to Ayzenberg’s layout is a simple design choice with predictable electrical benefits.
• Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges substituting Alden (Application # 2013/0280955) for Ayzenberg as the primary reference, arguing Alden similarly discloses a PCB with staggered inner and outer mounting pads, and then combining Alden with Lugthart and Janssen based on similar motivations.

4. Arguments Regarding Discretionary Denial

• Petitioner argued discretionary denial under §314(a) is unwarranted because there is no parallel litigation involving the ’898 patent, making the Fintiv factors inapplicable. Petitioner further argued that denial under §325(d) is improper because the grounds rely on prior art references (Ayzenberg, Alden, Lugthart, and Janssen) that were never considered or cited during the patent's prosecution. Because the asserted art and arguments are new and not cumulative to the art of record, Petitioner contended the grounds satisfy step one of the Advanced Bionics framework, making denial inappropriate.

5. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 1-20 of the ’898 patent as unpatentable.