PTAB

IPR2025-00822

Shenzhen FbTech Electronics Ltd v. LithiumHub Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Lithium Battery With Solid State Switch
  • Brief Description: The ’207 patent describes a lithium-based battery pack, such as for starting an internal combustion engine, that includes a solid-state switching apparatus. The apparatus comprises a plurality of pairs of solid-state switches connected in a parallel configuration to protect the battery and manage current flow.

3. Grounds for Unpatentability

Ground 1: Obviousness over Pevear, Poff, and Porsche - Claims 1-10 and 12-20 are obvious over Pevear in view of Poff and Porsche.

  • Prior Art Relied Upon: Pevear (Application # 2013/0101874), Poff (Application # 2007/0145944), and Porsche (“World Debut: Starter Battery in Lithium-Ion Technology,” Nov. 23, 2009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pevear disclosed a lithium-ion automotive starter battery with a battery management system and a cutoff component. However, Pevear’s cutoff component used two groups of parallel MOSFETs connected in series, not parallel pairs as claimed. To supply this missing element, Petitioner asserted that Poff taught an enhanced battery protection system with a conventional transistor pair and a redundant transistor pair connected in parallel to provide a cutoff function. Petitioner mapped Porsche’s disclosure of a 12V lithium-iron-phosphate starter battery with four cells and an 18 Ah nominal capacity to meet the claimed operating voltage, cell chemistry, and discharging amount limitations.
    • Motivation to Combine: A POSITA would combine Poff’s parallel switch pair configuration with Pevear’s battery system as a simple substitution of one known cutoff circuit for another to achieve improved and predictable voltage cutoff functionality. Both references address the same problem of protecting lithium-ion batteries. A POSITA would incorporate Porsche’s specific cell parameters into Pevear’s battery to realize the known weight-reduction and performance benefits of lithium-iron-phosphate cells in a standard 12V automotive system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying known techniques (Poff's parallel switch circuit) and components (Porsche's cells) to a known system (Pevear's battery) for their intended and understood purposes.

Ground 2: Obviousness over Pevear, Poff, Porsche, and Grant - Claims 11 and 21 are obvious over Pevear, Poff, Porsche, and Grant.

  • Prior Art Relied Upon: Pevear (Application # 2013/0101874), Poff (Application # 2007/0145944), Porsche (a 2009 press release), and Grant (Patent 4,166,241).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Pevear, Poff, and Porsche from Ground 1 to establish the base battery pack. To meet the limitations of claims 11 and 21, which added a "pair of cables" in "cable housing" with terminal clamps and connectors, Petitioner relied on Grant. Grant disclosed a battery jumpering apparatus with first and second cables routed through a case (housing) for connecting between two batteries, including a relay within the case.
    • Motivation to Combine: A POSITA would be motivated to add the cables and housing taught by Grant to the battery pack of the primary combination. The motivation was to provide a safe and integrated way to connect the battery, particularly for applications like jump-starting, without creating harmful sparks at the battery terminals, as taught by Grant.
    • Expectation of Success: Success was expected because it involved the straightforward addition of a conventional and well-understood component (cables with a housing and relay) to a battery pack to provide a known function.

Ground 3: Anticipation and Obviousness over Koebler - Claims 1-10 and 12-20 are unpatentable under 35 U.S.C. §§ 102 and 103 over Koebler.

  • Prior Art Relied Upon: Koebler (WO 2012/074548).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Koebler, a single reference, disclosed all limitations of the challenged claims. Koebler described a lithium-ion battery for a starter motor, including a protection circuit board with a solid-state cutoff switch (e.g., FETs). Crucially, Petitioner argued that Koebler explicitly taught connecting pairs of solid-state switches in parallel to "increase the current capabilities" and showed circuit diagrams with connected drains, directly corresponding to the core configuration of the challenged claims. Koebler also disclosed the claimed cell chemistries, discharging amounts, and charging voltage ranges, which Petitioner argued either anticipated the claims or rendered them obvious due to overlapping ranges.
    • Key Aspects: A central pillar of this ground was the argument that the ’207 patent was not entitled to its claimed priority date because new matter (e.g., specific voltage and capacity ranges) was added in the continuation-in-part application. Therefore, Koebler, published in 2012, qualified as prior art against the patent's effective filing date of March 13, 2015. Petitioner contended the Examiner clearly erred during prosecution by improperly disqualifying Koebler as a reference based on the parent application's filing date.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. It stated that parallel district court cases were stayed and that the co-pending ITC investigation would not resolve all patentability disputes, as claims 11 and 21 were not part of the ITC case.
  • Petitioner further contended that its invalidity grounds in the IPR (Grounds 1 and 2) did not overlap with its contentions in the ITC investigation.
  • Finally, Petitioner argued that the strength of its grounds weighed in favor of institution, particularly noting the Examiner's clear error in dismissing Koebler during prosecution, which meant the merits of the Koebler-based challenge (Ground 3) had never been substantively reviewed by the USPTO.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of the ’207 patent as unpatentable.