PTAB

PGR2019-00050

Samsung Electronics Co Ltd v. NuCurrent Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electrical System Incorporating a Single Structure Multimode Antenna for Wireless Power Transmission Using Magnetic Field Coupling
  • Brief Description: The ’100 patent describes a multi-mode antenna for wireless power transmission. The disclosed antenna uses a single, compact structure comprising a first outer coil electrically connected in series to a second interior coil to reduce the antenna’s footprint while enabling operation across multiple frequency bands.

3. Grounds for Unpatentability

Ground 1: Claims 1-25 Fail to Satisfy the Written Description Requirement under 35 U.S.C. §112(a)

  • Core Argument for this Ground: Petitioner argued that claims 1-25 are invalid because the specification fails to provide adequate written description support for the full scope of the claims, particularly for limitations added late in prosecution. The core of the challenge is a last-minute amendment that broadened claim 1 to cover coil arrangements that were never disclosed in the original application.
    • Unsupported Coil Configuration: Petitioner asserted that claim 1 was amended just before allowance to recite a second coil positioned "one of within an inner perimeter formed by an innermost turn of the first coil and adjacent the first coil." Petitioner argued this amendment impermissibly broadened the claim to cover a side-by-side coil arrangement. However, every embodiment and figure in the specification, and all arguments made during prosecution, exclusively describe and rely upon a concentric arrangement where the second coil is positioned within the first coil. The specification provides no disclosure that would have conveyed to a person of ordinary skill in the art (POSITA) that the inventor possessed an invention with side-by-side coils.
    • Unsupported "Third Gap" Limitation: The claim’s recitation of "a third gap separating an outermost turn of the second coil from the innermost turn of the first coil" further demonstrated the lack of support for a side-by-side embodiment. Petitioner contended this "third gap" concept is only coherent in the context of the disclosed concentric coil structure. For a side-by-side arrangement, the definition becomes nonsensical, as the distance measurement would necessarily include a portion of one of the coils itself, indicating the inventor never contemplated such a configuration.
    • Other Unsupported Limitations: Petitioner also identified several other limitations in the claims that allegedly lack adequate written description support:
      • Resonant Frequency Difference (Claim 1): The limitation requiring the resonant frequencies of the two coils to differ by "at least 100 kHz" was added just prior to allowance. Petitioner argued the specification provides no disclosure of this specific lower bound, only isolated examples with much larger frequency differences, and therefore does not support the claimed range.
      • Terminal Lead Portion (Claim 10): Claim 10 requires each terminal to have a lead portion that "extends over at least a portion of either of the first and second conductive wires." Petitioner argued that for the outermost terminal of the outer coil, as shown in the patent's figures, its lead portion would naturally extend away from the coil structure, not over it, rendering this feature unsupported.
      • Operating Frequency (Claims 13, 17, 18): Petitioner argued that the claimed lower frequency bound of "at least 10 kHz" is not mentioned in the specification. While it falls within a disclosed broad range of "1 kHz to about 10 GHz," Petitioner asserted that selecting this specific value from such an extremely broad range is akin to "picking a tree from a forest" and lacks descriptive support.
      • Inductance Range (Claim 23): The claimed unshielded inductance range of "between about 4.2 µH to about 8.2 µH" is not disclosed. The specification mentions these two values only as discrete measurements for two different inductor designs, not as the bounds of a continuous range.
      • Surface Area and Current (Claims 24-25): The limitations requiring a surface area "exceeding 120 mm" (claim 24) and a current "exceeding 500 mA" (claim 25) were added at allowance and allegedly have no corresponding disclosure in the specification.

Ground 2: Claims 1-25 Are Indefinite under 35 U.S.C. §112(b)

  • Core Argument for this Ground: Petitioner argued that the same claim-broadening amendment that renders the claims invalid for lack of written description also renders them indefinite. Because the claim language covers undisclosed side-by-side coil arrangements, a POSITA would be unable to determine the scope of the claims with reasonable certainty.
    • Indefinite "Third Gap": For the side-by-side coil arrangement now covered by claim 1, the term "third gap" is indefinite. A POSITA would not know how to measure the gap "separating an outermost turn of the second coil from the innermost turn of the first coil." It is unclear if this measurement should be between the nearest points, the furthest points, or some other set of points on the respective coils. The specification provides no guidance, as it only describes concentric coils.
    • Indefinite "Surface Area": Claim 24, which requires a coil to have a "surface area exceeding 120 mm," is indefinite for multiple reasons. First, a POSITA would not understand what constitutes the "surface area" of the coil—is it only the area of the conductive traces, the entire footprint including the gaps between traces, or the area inside the innermost turn? Second, the claim is facially deficient because it uses a unit of length ("mm") to describe an area, which is properly measured in square units (e.g., mm²). The specification provides no examples to clarify how this "surface area" should be determined.

4. Relief Requested

  • Petitioner requests institution of post-grant review and cancellation of claims 1-25 of the ’100 patent as unpatentable.