PTAB

IPR2025-01022

Astera Mfg Ltd v. ElectraLED Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: LED Light Fixture with Heat Management
  • Brief Description: The ’245 patent discloses an LED light fixture designed for improved thermal management. The core invention includes a housing with an integrated array of heat-dissipating fins that both define a rear receptacle for an internal power supply and passively dissipate heat generated by the LEDs without requiring a fan.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Lin - Claims 21-23, 25, and 26 are anticipated by or obvious over Lin.

  • Prior Art Relied Upon: Lin (TW Patent Application # TW94204571U)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lin, which was not considered during prosecution, discloses an "LED searchlight" that is nearly identical to the fixture claimed in the ’245 patent. Lin’s “heat dissipation unit” corresponds to the claimed housing and includes all key features of independent claim 21: a flange at its front end for mounting a “light-transmissive plate” (frontal lens), an internal receiver space, and a rear “plurality of heat dissipation fins” (array of fins). These fins define a recess at the back end for a “power supply unit,” corresponding to the claimed rear receptacle. Petitioner asserted Lin explicitly teaches that this fin structure dissipates heat to prolong LED service life, and its figures show this is achieved without a fan.
    • Key Aspects: Petitioner contended that dependent claims are also taught by Lin. Claim 22’s requirement for fins of different lengths is shown in Lin’s figures, creating the recess for the power supply. Claim 25’s mounting bracket is met by Lin’s “grab handle,” and claim 26’s use of fasteners to secure the lens to the flange is disclosed by Lin’s use of screws and baffle plates.

Ground 2: Obviousness over Chen - Claims 21-23 and 26 are anticipated by or obvious over Chen.

  • Prior Art Relied Upon: Chen (Patent 7,465,066)
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative primary reference, Petitioner argued that Chen, also not considered during prosecution, discloses an “illumination apparatus” that meets all limitations of claim 21. Chen’s tubular housing is made of a heat-conductive material and features a “plurality of heat-dissipating ribs” (array of fins) on its inner and outer surfaces. The front of the housing has a flange for mounting a “transparent plate” (frontal lens), and an internal “shoulder portion” acts as an internal receiver for the light engine. Petitioner contended that the internal fins and a “closed rear end” wall define an interior “receiving space” which functions as the claimed rear receptacle, within which Chen’s “driving unit” (power supply) is fixedly disposed. Heat is dissipated through the fins without a fan.
    • Key Aspects: Petitioner asserted that Chen’s disclosure of outer fins having different lengths meets the limitations of dependent claim 22, and its use of an “annular cap” with screw fasteners to secure the lens meets claim 26.

Ground 3: Obviousness over Lin in view of Zeng and Lodhie - Claim 24 is obvious over Lin in view of Zeng and Lodhie.

  • Prior Art Relied Upon: Lin (TW Patent Application # TW94204571U), Zeng (Application # 2006/0146553), and Lodhie (Patent 5,577,832)

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claim 24, which adds a thermal pad between the receiver and the PCB, with both having openings for a power supply lead. Petitioner argued Lin discloses the base fixture but lacks a thermal pad. Zeng, in the same field, taught interposing a thermal pad between an LED board and a heatsink to improve heat conduction. Lodhie taught passing power wires through holes in the PCB to keep connections short and prevent crimping.
    • Motivation to Combine: A POSITA would combine Zeng’s thermal pad with Lin’s fixture to further the shared goal of improving heat dissipation and prolonging LED life. A POSITA would also incorporate openings in the pad and PCB, as taught by Zeng and Lodhie, to provide a direct and protected pathway for power supply wires, which is a known and desirable design choice for wire management.
    • Expectation of Success: Petitioner argued success would be expected, as it involved the simple application of known components (a thermal pad and wiring holes) to a similar device to achieve predictable improvements in thermal performance and assembly.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Lin or Chen with Moriyama for adding Zener diodes (claim 27) and with Nishimoto and Cunningham for achieving specific operating temperatures (claim 28).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §314(a) and §325(d).
  • Fintiv Factors: Petitioner asserted that parallel district court cases are in the very early stages, with pending venue-related motions that must be resolved before any substantive proceedings like claim construction. Petitioner also noted a substantial non-overlap of issues, as the IPR challenges claims 21-28 while only claim 21 is at issue in the litigation. Finally, Petitioner stipulated it will not pursue in court any invalidity grounds raised or reasonably available in the IPR if review is instituted.
  • §325(d) Factors: Petitioner contended that denial under §325(d) is unwarranted because the primary prior art references, Lin and Chen, are highly material and were never considered by the examiner during the original prosecution.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 21-28 of the ’245 patent as unpatentable.