Amphenol Corp v. Credo Technology Group Ltd

1. Case Identification

• Case #: IPR2025-00699
• Patent #: 11,032,111
• Filed: April 10, 2025
• Petitioner(s): Amphenol Corporation
• Patent Owner(s): Credo Technology Group Ltd.
• Challenged Claims: 1-19

2. Patent Overview

• Title: Efficient Adaptation Interface for Transmitter Pre-Equalizers
• Brief Description: The ’111 patent relates to methods and systems for pre-equalizing high-data-rate communication signals to mitigate distortion in a transmission channel. The claimed invention involves storing multiple sets of pre-equalizer filter coefficients in registers, where each set corresponds to a different "channel model," and selecting an appropriate set to initialize an adaptive pre-equalization process.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lugthart-Das Sharma-Mezer - Claims 1-19 are obvious over Lugthart-706, Das Sharma, and Mezer.

• Prior Art Relied Upon: Lugthart-706 (Patent 9,882,706), Das Sharma (Application # 2014/0281067), and Mezer (Patent 7,239,665).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of these references taught every limitation of the challenged claims. Lugthart-706 disclosed the foundational system: an active cable with pluggable transceivers that perform pre-equalization (termed "pre-emphasis") on signals transmitted to a host device and that use a "training phase" to adjust equalizer parameters. Das Sharma taught making such a pre-equalization process adaptive by storing initial coefficients in registers on the transmitter side and then optimizing them during a training phase to improve performance. Mezer taught the key inventive concept of pre-computing and storing multiple, different sets of initial coefficients corresponding to different channel types (or "models") and selecting the appropriate set based on the connected channel to make the equalization process more efficient.
  • Motivation to Combine: A POSITA would combine Lugthart-706 and Das Sharma to implement a well-known adaptive pre-equalization technique to predictably improve the data transmission performance (i.e., lower the bit error rate) of Lugthart-706's active cable system. A POSITA would further incorporate Mezer's teachings to improve this combined system by storing different sets of initial coefficients for different channel models. This modification addressed the known problem of connecting pluggable cables to different hosts with varying channel characteristics (e.g., different PCB trace lengths) and provided the known benefit of a more efficient and faster-converging adaptive training process.
  • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success. The combination involved applying known techniques (adaptive equalization, using registers for storage, pre-storing multiple coefficient sets) to a conventional active cable system to achieve predictable and well-understood benefits, such as improved performance and increased efficiency. The individual components were standard in the art, and their integration was straightforward.

4. Arguments Regarding Discretionary Denial

• §314(a) / Fintiv Factors: Petitioner argued that discretionary denial under Fintiv is unwarranted because all factors favor institution. The petition was filed expeditiously, just four weeks after the patent owner filed complaints in district court and the ITC. As neither parallel proceeding is advanced (the ITC investigation has not been instituted), the PTAB's Final Written Decision (FWD) will likely issue before any trial or final determination in the other forums. Therefore, concerns of inefficiency and inconsistent results are minimal.
• §325(d) / Advanced Bionics Factors: Petitioner argued that denial under §325(d) is also unwarranted because the asserted prior art is not cumulative to the art considered during prosecution. None of the primary references (Lugthart-706, Das Sharma, Mezer) were cited or considered by the Examiner. Petitioner contended the claims were allowed based on the limitation of storing coefficients for "different channel models," a feature Petitioner alleges is explicitly taught by Mezer and made obvious by the combination. This constitutes a material, unaddressed argument that warrants review.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-19 of the ’111 patent as unpatentable.