PTAB

IPR2025-01288

Dell Technologies Inc v. Cloud Byte LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: ICT Equipment
  • Brief Description: The ’320 patent relates to Information and Communication Technology (ICT) equipment, such as a server, featuring a cooling system that manages fan speed. The system uses both the temperature of an internal electronic component and the temperature of intake air to control the rotations of a cooling fan, particularly by calculating a "declination index value" representing the rate of component temperature decrease.

3. Grounds for Unpatentability

Ground 1: Claims 1-8 are obvious over Sato in view of Nakamura.

  • Prior Art Relied Upon: Sato (Application # 2011/0176275) and Nakamura (Japanese Patent No. JP4511444B2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sato discloses nearly all elements of the challenged claims, including ICT equipment (a server) with a cooling fan, a first sensor for an electronic component temperature, a second sensor for intake air temperature, and a microprocessor-based controller that uses both temperatures to control fan speed. Petitioner contended the only element missing from Sato is the calculation of a "declination index value indicating a degree of declination of the component temperature." Nakamura allegedly remedies this deficiency by teaching a fan control program that explicitly calculates the "rate of temperature decrease" (the claimed index value) to determine if a component's temperature has stagnated, allowing the fan to be slowed or stopped.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Sato and Nakamura to improve the efficiency of the cooling system. Both references address the same problem of reducing fan noise and power consumption in electronic devices. Petitioner asserted a POSITA would enhance Sato’s system, which adjusts fan speed but does not stop the fans, by incorporating Nakamura’s technique for detecting temperature stagnation. This would allow the system to stop the fans when cooling is no longer needed, furthering Sato’s stated goals.
    • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success. Sato’s system is controlled by a microprocessor (MPU), and Nakamura’s method is a software-based control program. Modifying Sato’s fan control software to implement Nakamura’s logic for calculating the rate of temperature decrease would have been a straightforward programming task involving known methods to yield predictable results.

Ground 2: Claim 3 is obvious over Sato and Nakamura in view of Jin.

  • Prior Art Relied Upon: Sato (Application # 2011/0176275), Nakamura (Japanese Patent No. JP4511444B2), and Jin (Korean Application # 10-2010-0028353).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addresses claim 3, which recites that the index value is an "average value of declination rates of the component temperature...in a plurality of measurement periods." Petitioner argued that while the Sato-Nakamura combination teaches calculating a declination rate, Jin explicitly discloses a method that meets the "average value" and "plurality of periods" limitations. Jin teaches a temperature control technique that calculates and compares two distinct average rates of temperature change: one over a longer, overall period (L) and another over a more recent period (P). This method of using average rates over multiple periods directly corresponds to the language of claim 3.
    • Motivation to Combine: A POSITA would be motivated to incorporate Jin's teachings into the Sato-Nakamura combination to create a more robust and accurate cooling control system. Jin's method of analyzing both long-term and short-term temperature trends provides more accurate predictions of temperature stagnation than the methods in Nakamura alone. Since both Nakamura and Jin rely on the same type of sampled temperature data, a POSITA would see Jin’s technique as a compatible and advantageous improvement for more efficiently controlling the fan and further reducing noise and power consumption.
    • Expectation of Success: Petitioner asserted that integrating Jin's predictive algorithm would be well within the skill of a POSITA. The modification would primarily involve basic programming changes to the fan control logic established by the Sato-Nakamura combination, as Jin's method is a logical extension using the same type of sensor inputs.

4. Key Claim Construction Positions

  • "declination index value calculation unit" and "control unit": Petitioner contended that these terms should be given their plain and ordinary meaning and should not be construed as means-plus-function limitations under 35 U.S.C. §112, ¶6, as they do not use "means for" language and recite sufficient structure.
  • Alternative Construction: Should the Board find these terms are means-plus-function, Petitioner proposed corresponding structures from the specification. For the "declination index value calculation unit," the function is calculating the index value, and the structure is the disclosed "CPU 13" configured to perform that calculation. For the "control unit," the function is controlling the fan's rotations, and the structure is the "CPU 13" configured to implement the "control means 172" in the "management section 17."

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-8 of Patent 9,651,320 as unpatentable.