PTAB

IPR2025-01141

Apple Inc v. LS Cable & System Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Contactless Battery Charging
  • Brief Description: The ’568 patent discloses a system for contactless battery charging that purports to overcome restrictions on the relative positioning of a charger and a battery. The system aims to provide user convenience while preventing overvoltage conditions that could damage the battery.

3. Grounds for Unpatentability

Ground 1: Obviousness over Baarman-878, NCP1800 Datasheet, and Horowitz - Claims 1, 5, 7, 8, 11, 13-19, 21, 23, 25-49, 52, 54-58

  • Prior Art Relied Upon: Baarman-878 (Patent 7,522,878), NCP1800 Datasheet (a May 2003 publication by ON Semiconductor), and Horowitz (a 1989 electronics textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references teaches all limitations of the challenged claims. Baarman-878 disclosed a complete contactless energy transmission system that uses magnetic induction to transfer power from a primary winding in a power supply to a secondary winding in a remote device, meeting the core wireless charging elements of claim 1. However, Baarman-878 did not explicitly detail converting the induced AC to DC or the specific implementation of its charge controller. Petitioner asserted that Horowitz, a foundational electronics textbook, taught the necessity and method of using a rectifier circuit to convert AC to DC for charging a battery. To supply the claimed constant voltage/constant current (CCCV) and overvoltage monitoring functions, Petitioner pointed to the NCP1800 Datasheet. This datasheet described a widely used CCCV lithium-ion battery charge controller that monitors both its input voltage (VCC) and output battery voltage (VSNS) to provide overvoltage protection and manage charging stages, thus fulfilling the limitations for the CCCV supplier and overvoltage monitoring unit.
    • Motivation to Combine: A POSITA would combine these references to create a functional and safe wireless charger. The motivation to add Horowitz's rectifier to Baarman-878 was fundamental, as a POSITA would know that induced AC must be converted to DC to charge a battery. A POSITA would be motivated to implement Baarman-878's generic controller using the specific, off-the-shelf CCCV controller from the NCP1800 Datasheet to achieve the well-known, safe, and effective CCCV charging method required for lithium-ion batteries. This would also inherently provide the overvoltage protection described in the datasheet.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success. The combination involved applying known solutions (rectification, CCCV charging) to their intended purposes using well-understood, predictable components to solve a known problem.

Ground 2: Obviousness over Baarman-878, NCP1800 Datasheet, Horowitz, and Veselic - Claims 3, 4, 6, 9, 10, 12, 20, 22, 24, 50, 51, 53

  • Prior Art Relied Upon: Baarman-878 (Patent 7,522,878), NCP1800 Datasheet, Horowitz, and Veselic (Patent 7,791,319).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1, adding Veselic to provide explicit teachings for limitations in certain dependent claims. Specifically, for claims requiring a "voltage comparator" (e.g., claim 3) or monitoring a "difference of voltages" (e.g., claim 6), Veselic disclosed using a voltage sensing circuit to measure the voltage drop across a battery charge controller (such as the NCP1800). Veselic taught comparing the input and output voltages of the controller to determine power consumption. Petitioner argued this teaching directly supplied the missing limitation of comparing the two voltages monitored by the NCP1800 chip.
    • Motivation to Combine: A POSITA would be motivated to incorporate Veselic's teachings to gain the technical advantages it described. Veselic's method allowed for precise power consumption control, enabling the charger to operate within the limits of a power source (like a USB port) and to mediate power competition between charging the battery and powering the device. These were known problems for which a POSITA would seek known solutions.
    • Expectation of Success: Success would be expected, as Veselic expressly suggested its techniques could be applied to standard "off the shelf" controllers like the NCP1800 without redesign.

Ground 3: Obviousness over Baarman-267 and Veselic - Claims 1, 3, 7-9, 11, 12, 30-34, 48-50, 52, 53

  • Prior Art Relied Upon: Baarman-267 (Patent 7,518,267) and Veselic (Patent 7,791,319).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented an alternative combination starting with Baarman-267, which disclosed a contactless charging adapter system. Baarman-267 taught a power regulator that provides a CCCV output to a battery cell and receives DC from a rectifier, thus teaching several limitations of claim 1. However, like Baarman-878, it lacked specific details on how its controller implemented overvoltage monitoring and control. Petitioner argued that Veselic supplied these missing details by teaching a method to monitor and control a CCCV battery charger. Veselic’s disclosure of using a voltage comparator to monitor the voltage drop across a charge controller was argued to render the claimed overvoltage monitoring unit obvious.
    • Motivation to Combine: A POSITA would combine Baarman-267 and Veselic to implement the generic controller of Baarman-267 with the specific, advantageous control strategy from Veselic. As in Ground 2, the motivation was to realize the technical benefits described in Veselic, such as managing power consumption from limited sources like a USB port, which Baarman-267’s device could be connected to.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because both references utilized well-known components like microcontrollers and CCCV circuits in analogous ways. Veselic provided detailed guidance, schematics, and flow charts for implementing its teachings.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors was inappropriate. The basis for this argument was that no trial date had been set in the parallel district court litigation, meaning no Fintiv issues were presented at the time of filing.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1 and 3-58 of the ’568 patent as unpatentable.