PTAB

PGR2021-00070

Precision Power LLC v. PowerTec Solutions Intl LLC

Key Events

Petition

petition

Title: Uninterruptible Power Supply (UPS) System
Brief Description: The ’954 patent describes a modular, expandable uninterruptible power supply system. The system comprises a main power supply unit that accepts AC power and one or more external, stackable battery packs that can be mechanically and electrically interconnected to the power supply and each other using specific arrangements of connectors, feet, and grooves.

Prior Art Relied Upon: Shen-599 (Patent 8,665,599).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Shen-599, which discloses a "Portable External Power-Supplying Device," anticipates every limitation of the challenged claims. Shen-599 teaches a system with a power control module and a plurality of modular, stackable battery units. Petitioner asserted that Shen-599's battery units (e.g., unit 2) are modular external battery packs that include a housing with opposing faces, a first electrical connector and mechanical connector on one face, and a second, different type of electrical/mechanical connector on the opposite face, configured for interlocking with other units. For claim 13, Petitioner contended that Shen-599’s retaining hooks (28) and positioning pins (27) constitute "feet," and its positioning holes (271) and fixing holes (281) constitute "interlocking grooves."

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 teaches the fundamental elements of an expandable UPS system with hot-swappable battery modules, including an AC input and DC output to power a device and charge the batteries. However, Chang-085 does not detail a specific stacking mechanism. Petitioner contended that Shen-599 provides the missing physical implementation, teaching a well-defined form factor with the specific mechanical (feet/grooves) and electrical connectors for stacking a power module and battery units, as recited in the claims. The combination of Chang's UPS functionality with Shen's physical design renders the claims obvious.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would be motivated to combine the teachings because both references address the same problem of providing scalable, swappable backup power. A POSITA would combine Chang's established UPS circuit concept with Shen's known and beneficial mechanical stacking structure to create a user-friendly, modular, and commercially practical product.
- Expectation of Success: A POSITA would have a high expectation of success because the combination involves applying a known mechanical interface (Shen-599) to a standard electrical system (Chang-085), a predictable integration of known technologies.

Prior Art Relied Upon: Chang-085 (Application # 2005/0052085), Shen-599 (Patent 8,665,599), and Lemelman-583 (Application # 2013/0069583).
Core Argument for this Ground:
- Prior Art Mapping: This ground builds upon the Chang-085 and Shen-599 combination by adding Lemelman-583 to supply any elements arguably missing from the primary combination. Petitioner argued that Lemelman-583, which discloses a "Power Module for Portable Devices," explicitly teaches various interlocking features like hooks, slots, rails, and latches (feet and grooves) for securing stackable battery modules to a power supply (a phone case). For claim 2, Lemelman-583 expressly discloses the use of a "rechargeable Lithium Polymer battery," teaching the claimed lithium-based cell.
- Motivation to Combine: A POSITA, having combined Chang and Shen, would consult a reference like Lemelman-583 for known methods to refine the design. If seeking to improve the mechanical connection or select an appropriate battery chemistry, a POSITA would find it obvious to incorporate Lemelman's disclosed use of lithium-based cells and its robust feet-and-groove connection mechanisms to yield the claimed invention.

Core Argument for this Ground: Petitioner argued that numerous claims are indefinite for failing to particularly point out and distinctly claim the subject matter. Three primary issues were identified:
- Mismatched Terms: Claim 3 recites a "first face" on the power supply and a "first face" on the battery pack, then refers to a second face "opposite said first face" without specifying which "first face" it is opposite to. This ambiguity, Petitioner argued, makes the claim indefinite.
- Unclear Number: Claim 6 twice recites "a third electrical connector of a first type," making it unclear whether one or two such connectors are required. Similarly, claims 14 and 16 recite multiple instances of "power supply" without clarifying if they refer to the same or different components.
- Ambiguous Method Steps: Claim 6 requires applying AC power and providing backup power "when the power input fails," creating a logical inconsistency. Claim 8 uses the phrase "selected to be," which implies an action without reciting it as a required step, rendering the scope unclear.
Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 10, 12, and 13 over the combination of Shen-599 and Lemelman-583, and claim 16 over the combination of Chang-085, Shen-599, and Krieger-326 (Application # 2007/0273326).

Petitioner requested that the Board institute a post-grant review and cancel claims 1-16 of the ’954 patent as unpatentable.