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IPR2025-01287

Dell Technologies Inc v. Cloud Byte LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cooling Structure of Electronic Device
  • Brief Description: The ’265 patent discloses a cooling structure for electronic devices, such as servers, designed to improve thermal efficiency. The invention focuses on a specific component layout where multiple power source units are positioned on opposite sides of the device housing, spaced apart and not linearly aligned with the CPU, to prevent heat transfer between the units and improve cooling airflow.

3. Grounds for Unpatentability

Ground 1: Obviousness over Carl and Hughes - Claims 1-8 are obvious over Carl in view of Hughes.

  • Prior Art Relied Upon: Carl (Patent 9,332,679) and Hughes (Application # US 2008/0218949).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Carl teaches a server architecture with nearly all the claimed elements: a housing, front-mounted fans pushing air downstream over a CPU, memory modules adjacent to the CPU, and downstream power supplies. However, Carl discloses its two power supplies positioned side-by-side near one edge of the enclosure. Hughes was introduced as it discloses a server enclosure with two power supply units explicitly positioned on opposite sides. The combination of Carl's core layout with Hughes's power supply placement was alleged to render the claims obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Carl and Hughes to achieve predictable benefits. Hughes teaches that positioning heavy power supplies on opposite sides improves structural support and balance within a server rack. Petitioner asserted a POSITA would also recognize that separating the power supplies, as taught by Hughes, improves thermal management by creating more uniform airflow and preventing one power supply from heating the other—addressing the very problem solved by the ’265 patent.
    • Expectation of Success: Modifying the layout of power supplies was a common design choice in the field of server architecture. Petitioner contended that repositioning the power supplies from Carl's design according to the clear teachings of Hughes would be a straightforward modification with a high expectation of success.

Ground 2: Obviousness over Okamoto - Claims 1, 4, 5, 7, and 8 are obvious over Okamoto.

  • Prior Art Relied Upon: Okamoto (Patent 7,643,281).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Okamoto, a single prior art reference disclosing a storage controller, teaches every limitation of the independent claims. Petitioner mapped Okamoto's components to the claims: cooling fans (71, 72, 73) create downstream airflow; a microprocessor (131) functions as the CPU; storage devices (20) serve as the memory devices; and either batteries (60) or power devices (50) function as the power source units. Crucially, Okamoto’s figures show these power source units arranged in bilateral symmetry on opposite sides of the housing, downstream from the memory devices, and not linearly aligned with the CPU, allegedly disclosing the core inventive concept of the ’265 patent.
    • Key Aspects: This ground posits that no combination is necessary because Okamoto's disclosed embodiment inherently contains the specific component layout claimed in the ’265 patent, rendering the invention obvious.

Ground 3: Obviousness over Okamoto and Hughes - Claim 2 is obvious over Okamoto in view of Hughes.

  • Prior Art Relied Upon: Okamoto (’281 patent) and Hughes (’949 application).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the assertion that Okamoto teaches all limitations of claim 1 and addresses dependent claim 2, which adds the limitation that the power source units are "arranged to be pulled out from the rear face of the housing." Petitioner argued that while Okamoto does not explicitly disclose this feature, Hughes teaches power supply modules designed for convenient insertion and removal from bays in the rear of an enclosure.
    • Motivation to Combine: A POSITA would incorporate the removable power supplies of Hughes into Okamoto’s design to gain the well-known and highly desirable benefit of hot-swappability. This would allow for easy replacement of defective or damaged power units without system downtime, a critical feature for enterprise-grade storage controllers like the one disclosed in Okamoto.
    • Expectation of Success: Implementing rear-removable, hot-swappable power supplies was a standard and well-understood practice in the relevant art, ensuring a POSITA would have a reasonable expectation of successfully making this modification.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1-8 are obvious over Carl in view of Suzuki; claims 2 and 3 are obvious over Carl/Hughes or Carl/Suzuki further combined with Wiscombe; and claims 2, 3, and 6 are obvious over Okamoto combined with Hughes, Suzuki, or Wiscombe. These grounds relied on similar rationales, presenting Suzuki as an alternative to Hughes for teaching separated power supplies and Wiscombe for teaching removable power supply structures.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the term "the plurality of electronic parts" found in dependent claim 3, which lacks a clear antecedent basis in the claims.
  • Based on the patent's prosecution history, where a "plurality of electronic parts" was amended to a single "central processing unit," Petitioner proposed that the term should be construed to mean the "central processing unit (CPU)" of claim 1. This construction clarifies that the power source units are positioned to avoid interfering with cooling air flowing from the CPU.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8 of Patent 9,629,265 as unpatentable.