PTAB

PGR2021-00043

Precision Power LLC v. PowerTec Solutions Intl LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Modular Stackable Uninterruptible Power Supply
  • Brief Description: The ’264 patent relates to a switchable direct current (DC) voltage supply system, such as an uninterruptible power supply (UPS), comprising a main power supply unit and at least two external, stackable battery packs. The system uses mating electrical and mechanical connectors to physically and electrically couple the units, allowing for expandable standby power capacity.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chang-085 and Shen-599 (Claims 1, 3-7)

  • Prior Art Relied Upon: Chang-085 (Application # 2005/0052085) and Shen-599 (Patent 8,665,599).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chang-085 taught the core functionality of an expandable UPS system with an alternating current (AC) input, DC output, and hot-swappable battery modules to increase power capacity. However, Chang-085 lacked a specific physical implementation for modular connection. Petitioner asserted that Shen-599 supplied this missing element by disclosing a "Portable External Power-Supplying Device" with a main power control module and a plurality of removably stackable battery units. Shen-599 explicitly taught the use of interconnecting mechanical features (e.g., feet, grooves, positioning pins, retaining hooks) and corresponding electrical ports to securely stack and connect its modules, which Petitioner mapped to the limitations of claims 1, 3, and 5.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Chang-085 and Shen-599 to implement the scalable UPS concept of Chang-085 with the user-friendly, modular form factor taught by Shen-599. The combination was presented as a predictable integration of a known system (expandable UPS) with a known mechanical design (stackable modules with feet/grooves) to yield a simple-to-use, scalable power supply.
    • Expectation of Success: A POSITA would have a high expectation of success because the combination involved applying a known mechanical attachment method to a known electrical system, presenting no significant technical hurdles.

Ground 2: Obviousness over Chang-085 and Lemelman-583 (Claims 1, 3-7)

  • Prior Art Relied Upon: Chang-085 (Application # 2005/0052085) and Lemelman-583 (Application # 2013/0069583).
  • Core Argument for this Ground:
    • Prior Art Mapping: In this alternative ground, Petitioner again relied on Chang-085 for the foundational expandable UPS system. Lemelman-583 was asserted to teach a similar modular and stackable power system, specifically a phone case (power supply) with stackable external battery packs ("Universal Power Modules" or UPMs). Lemelman-583 disclosed various mechanical interconnects, including hooks, slots, rails, and retention latches, for securing the UPMs to the case and to each other. It also taught electrical Inter-Module Interconnect (IMI) contacts on opposing faces of the UPMs for power transfer, which Petitioner mapped to the connector limitations of independent claims 1, 3, and 5.
    • Motivation to Combine: The motivation was analogous to the first ground. A POSITA seeking to improve the usability of Chang-085's scalable UPS would look to known modular designs like that in Lemelman-583. Adopting Lemelman-583’s particular form factor and its mechanical and electrical structures would be an obvious design choice to create a versatile and easily reconfigurable UPS.
    • Expectation of Success: Success was expected because it involved the straightforward application of Lemelman-583's established modular design principles to the standard UPS architecture of Chang-085.

Ground 3: Indefiniteness under 35 U.S.C. § 112 (Claims 1-7)

  • Prior Art Relied Upon: Not applicable.

  • Core Argument for this Ground: Petitioner argued that claims 1-7 are invalid as indefinite for failing to inform a POSITA of the scope of the invention with reasonable certainty. Four categories of issues were identified:

    • Mismatched or Unmatched Terms: Petitioner contended that terms like "said at least one battery" and "said first face" were used ambiguously. For example, after introducing a battery in a first pack and a battery in a second pack, subsequent recitations of "said at least one battery" did not specify which battery was being referenced.
    • Undefined Terms: The term "switchable" in the preamble of claim 1 was alleged to be an uncommon term for a power supply, in contrast to the well-understood term "switching," which is used in the claim body. The specification allegedly provided no definition, rendering the scope of "switchable" unclear.
    • Lack of Antecedent Basis: The term "power pack" was used in claims 1 and 2 (e.g., "power pack connection terminals," "each said power pack") without a proper antecedent introduction, creating ambiguity as to what "power pack" refers.
    • Ambiguous Method Steps: Petitioner argued that method claim 5, which recites an action occurring "when the power input fails," is ambiguous because it is unclear whether the failure of the power input is a condition precedent or a required step of the claimed method.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claim 2 by adding Yumoto-023 (Application # 2008/0076023) to the primary combinations. Yumoto-023 was cited to teach the use of specific lithium-based battery chemistries (e.g., LiCoO2, LiMn2O4) recited in dependent claim 2, which a POSITA would have been motivated to incorporate as a well-known and predictable design choice.

4. Relief Requested

  • Petitioner requested institution of Post-Grant Review and cancellation of claims 1-7 as unpatentable.