PTAB

IPR2025-00834

Amphenol Corp v. Credo Technology Group Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Active Ethernet Cables with Bi-Directional Signal Equalization
  • Brief Description: The ’252 patent describes active high-speed data cables containing transceivers at each end. The invention purports to lie in the transceivers' use of distinct equalization schemes: fixed, cable-independent parameters for signals at the host interface and different, potentially adaptive, cable-dependent parameters for signals transmitted over the cable itself.

3. Grounds for Unpatentability

Ground 1: Claims 1-14 are obvious over Lugthart in view of Aronson

  • Prior Art Relied Upon: Lugthart (Patent 9,337,993) and Aronson (Patent 7,762,727).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lugthart disclosed an active cable with transceivers featuring distinct signal processing paths that perform all claimed steps. Lugthart’s architecture includes equalization and clock and data recovery (CDR) for inbound data from a host, and a separate CDR and pre-equalization for outbound data to the host. During prosecution, the Examiner found that Lugthart anticipated the original independent claims except for the limitation requiring "fixed, cable-independent equalization parameters" for host-side processing. Petitioner asserted that Aronson remedies this deficiency by explicitly teaching active cables that use "cable-independent" equalization for losses on "host board traces" and "cable-dependent" parameters for losses over the copper cable. Aronson further teaches that this host-side equalization can be "fixed," presenting it as a known design choice to reduce complexity and cost.
    • Motivation to Combine: A POSITA implementing Lugthart's active cable, which already separates host-side and line-side signal processing via its CDR placement, would be motivated to apply Aronson's corresponding equalization strategies. Using fixed, cable-independent parameters for the standardized host interface is a logical step to reduce costs, while using different, potentially adaptive, parameters for the variable cable portion optimizes performance. This represents the application of a known technique to a known system to achieve predictable results.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involves applying a standard equalization technique described in Aronson to the compatible and well-defined system architecture of Lugthart's active cable.

Ground 2: Claims 1-4, 6-9, and 11-14 are obvious over Tang, TI-Retimer, and Aronson

  • Prior Art Relied Upon: Tang (Application # 2013/0115803), TI-Retimer (DS125DF1610 Retimer Datasheet, Mar. 2017), and Aronson (Patent 7,762,727).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented a combination where Tang provides the framework of an active Ethernet cable with "signal drivers" (e.g., CDRs). The TI-Retimer datasheet describes a commercial retimer chip with the specific circuitry—an equalizer (EQ), CDR, and transmit FIR filter—to fully implement Tang’s drivers. Petitioner argued that implementing Tang’s drivers with the TI-Retimer chip is a simple substitution of a known element. This combination creates a complete active cable system. Aronson was then added to this base system to supply the specific equalization strategy: using fixed, cable-independent parameters for host-side equalization and cable-dependent parameters for the line side. This combination was argued to render independent claims 1, 6, and 11 obvious.
    • Motivation to Combine: A POSITA would combine Tang’s cable with an off-the-shelf component like the TI-Retimer chip to implement the signal drivers. Once combined, the motivation to incorporate Aronson's teachings is to apply a known, superior equalization method to the system. Furthermore, Aronson’s teachings on the design trade-offs between fixed and adaptive equalization for the cable-dependent parameters would render dependent claims 3 (adaptive) and 4 (fixed) obvious, as they represent pursuing a finite number of identified, predictable solutions.
    • Expectation of Success: Petitioner asserted a high expectation of success, as using a commercial chip to implement a functional block is standard industry practice, and applying conventional equalization methods from Aronson to the resulting system would be a straightforward engineering task.

4. Key Claim Construction Positions

  • Petitioner argued that claim 7 contains a publication error rendering it agrammatical and nonsensical. It contended the claim should be construed without the erroneous, unexamined language ("each employ fixed, cable-independent, equalization parameters") to be consistent with its dependency on claim 6 and the prosecution history.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under both 35 U.S.C. §314(a) and §325(d).
  • Fintiv Factors: Petitioner asserted that denial under Fintiv is unwarranted because the petition was filed expeditiously, only four weeks after parallel district court and ITC complaints were filed and before any substantive progress in those cases. Petitioner argued a Final Written Decision (FWD) would likely issue before any trial or final determination in the parallel proceedings, favoring institution.
  • Advanced Bionics Factors: Petitioner argued that denial under §325(d) is inappropriate. For Ground 1, the Examiner never considered the Lugthart-Aronson combination, and material error occurred by overlooking Aronson's explicit teaching of the "fixed, cable-independent" parameters that formed the basis for allowance. For Ground 2, the primary references (Tang and TI-Retimer) were never considered by the Office, meaning the argument was never presented or considered.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-14 of Patent 11,012,252 as unpatentable.