Apple Inc v. Vampire Labs LLC

1. Case Identification

• Case #: IPR2025-01215
• Patent #: 8,358,103
• Filed: June 27, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): Vampire Labs, LLC.
• Challenged Claims: 1-14

2. Patent Overview

• Title: Inductive Battery Charging System
• Brief Description: The ’103 patent relates to battery charging systems that purport to limit "vampiric" power consumption. The system automatically couples an inductive charging unit to an AC power source when a device's battery is below a threshold and decouples it when a desired charge state is reached.

3. Grounds for Unpatentability

Ground 1: Claims 1-6, 8, 9, and 11-14 are obvious over Stephens in view of Horowitz.

• Prior Art Relied Upon: Stephens (Patent 5,734,254) and Horowitz (a 1989 electronics textbook titled "THE ART OF ELECTRONICS").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Stephens, which discloses an inductive charging system for portable devices, teaches the core limitations of claim 1. Stephens's system includes a controller (50) that communicates with proximity sensors (38, 68) to determine when a device is coupled for charging (the "connection module"). The controller also receives "sensed battery conditions" to determine charge level (the "monitoring module"). Based on these conditions, the controller provides signals to a power selector (60) to couple or decouple the primary transformer winding from an AC input, thereby automatically starting or stopping charging (the "activation" and "separation" modules). Petitioner asserted Stephens’s disclosure of "decoupling relays" meets the claim limitation of a relay switch.
  • Motivation to Combine: Petitioner contended that while Stephens discloses using "decoupling relays," it does not provide specific implementation details. A person of ordinary skill in the art (POSITA) seeking to implement such relays would be motivated to consult an authoritative textbook like Horowitz for guidance. Horowitz was described as a comprehensive text that explains the advantages of using relays for switching AC power, such as electrical isolation of control signals, which is directly analogous to the function of the power selector in Stephens.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because implementing relays as taught by Horowitz into the known charging circuit of Stephens involved applying well-understood principles to achieve predictable results.

Ground 2: Claims 1, 2, and 9-11 are obvious over Toya in view of Horowitz.

• Prior Art Relied Upon: Toya (Application # 2008/0061733) and Horowitz.

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that Toya teaches an inductive battery charger that meets the limitations of claim 1. Toya's controller (25) and electronic equipment detection circuit (16) determine if a target device is positioned for charging ("connection module"). A "full charge detection circuit" (59) determines when the battery is fully charged, meeting the "monitoring module" limitation. The controller (25) automatically turns switches (23) on or off to couple or decouple the inductive power apparatus from the AC power source based on the battery's charge state, satisfying the "activation" and "separation" module limitations.
  • Motivation to Combine: Petitioner argued that Toya discloses the use of switches (23) but does not specify their type. A POSITA would be motivated to look to a standard reference like Horowitz for implementation details and would combine Toya’s system with the relay switches described in Horowitz. The motivation is to realize the known advantages of relays for high-voltage switching and to electrically isolate the low-voltage controller from the higher-voltage power signals, a common design goal.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in incorporating Horowitz's standard relay designs into Toya's charging system, as it was a straightforward application of established electronic principles.

• Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 3) against claims 3-7 and 12-14 based on the combination of Toya, Stephens, and Horowitz, arguing a POSITA would combine elements from each reference to arrive at the claimed invention.

4. Key Claim Construction Positions

• Petitioner argued that several "module" terms recited in the claims should be construed as means-plus-function limitations under 35 U.S.C. § 112(f) if the Board deems it necessary.
• For each module (e.g., "connection module," "monitoring module," "activation module," "separation module"), Petitioner provided the claimed function and identified the corresponding structure from the ’103 patent's specification and figures. This position is central to Petitioner's strategy, as it frames the invalidity analysis by defining the specific structures the prior art must disclose or render obvious.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv is not warranted. The petition noted that no trial date has been set in the co-pending district court litigation (Vampire Labs, LLC v. Apple, Inc., W.D. Tex.), and therefore no Fintiv issues are present.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’103 patent as unpatentable.