PTAB

IPR2026-00005

Nintendo Co Ltd v. Malikie Innovations Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: DEVICE FOR A PORTABLE ELECTRONIC DEVICE
  • Brief Description: The ’247 patent relates to charging and data transfer docks for portable electronic devices. The invention purports to solve the problem of connector damage from misalignment by using a support for the connector that includes an elastically deformable portion, allowing the connector to move relative to the dock when a force is applied.

3. Grounds for Unpatentability

Ground 1: Obviousness over Tsutsui - Claims 1-2, 6, 11, 13, 15-16, and 19 are obvious over Tsutsui.

  • Prior Art Relied Upon: Tsutsui (Japanese Application # JP2005085593A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tsutsui discloses all limitations of the challenged claims. Tsutsui teaches a cradle (dock) for a portable electronic device that explicitly addresses the same problem of preventing connector damage from misalignment. Independent claim 1’s requirement for "a support coupled to an inner wall of the housing, a portion of the support being elastically deformable" was allegedly met by Tsutsui's "cushioning member 3." This member is described as being made from a rubber or urethane-based material with "excellent elasticity" and is fixed to the cradle body via a resin mold, coupling it to an inner wall of the housing. The connector is received within this cushioning member, which acts as the support. The claimed "collar abutting the connector" was mapped to the inner portion of the cushioning member that surrounds the connector, limiting its translation while allowing it to pivot. Dependent claims were mapped to further disclosures in Tsutsui, such as the cushioning member serving as a "spring component" (claim 2) and the connector being a "charging connector" (claim 11).
    • Motivation to Combine (for §103 grounds): As this ground relied on a single reference, Petitioner asserted that Tsutsui itself provided the motivation. Tsutsui identified the problem of connector damage due to misalignment during docking and explicitly taught the claimed solution: using an elastic, cushioning support structure to absorb stress and allow the connector to float. A person of ordinary skill in the art (POSITA) reviewing Tsutsui would have been motivated to implement its teachings to solve this known problem.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because Tsutsui explicitly stated its cushioning member "adequately absorbed" the stress from misalignment, thereby "reliably prevent[ing]" damage to the connector while ensuring a reliable electrical connection.

4. Key Claim Construction Positions

  • Petitioner contended that no terms required express construction because the challenged claims are obvious under any reasonable interpretation.
  • In the parallel district court litigation, Petitioner proposed constructions for key disputed terms. For "support," Petitioner proposed "a structure that limits movement in a direction." This construction was argued to be met by Tsutsui's cushioning member, which supports the connector and limits its movement. For "inner wall," Petitioner proposed "internal upright or vertical structure enclosing a space," which was allegedly disclosed by the internal surfaces of Tsutsui's cradle body to which the cushioning member is fixed.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) was not warranted. The petition asserted that this was the first and only inter partes review (IPR) filed against the ’247 patent and its validity had not been previously adjudicated. Furthermore, the primary prior art reference, Tsutsui, was not considered during the original prosecution of the ’247 patent. Petitioner also noted that the co-pending district court litigation was in a relatively early stage and that it intended to move to stay the litigation pending the outcome of the IPR.

6. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-2, 6, 11, 13, 15-16, and 19 of the ’247 patent as unpatentable under 35 U.S.C. §103.