PTAB

PGR2022-00009

Home Depot USA Inc v. Lynk Labs Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Voltage and Multi-Brightness LED Lighting Devices and Methods of Using Same
  • Brief Description: The ’341 patent describes an LED lighting device containing at least two distinct LED circuits. The device includes a switch that allows a user to configure the circuits for multi-voltage or multi-brightness operation by, for example, changing the voltage supplied to the circuits or switching additional circuits on or off.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1, 3, 5, 7-8, 10, 12, 14-15, 17, and 19 are anticipated by Bruning.

  • Prior Art Relied Upon: Bruning (Application # 2002/0070914).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Bruning, which discloses a control and drive circuit for an LED backlight, teaches every limitation of the challenged claims. Bruning’s red, green, and blue LED sub-array circuits (210R, 210G, 210B) met the limitations for a "first operating LED circuit" and "at least one additional LED circuit" of a different color. Petitioner contended Bruning's "panel light setting" switch, which controls the duty cycle of transistor switch Q1 to adjust the voltage (VRO, VGO, VBO) applied to the LED circuits, constituted the claimed "switch" capable of "switching a voltage level input" or "switching a brightness level." The system is configured to connect to an AC power source, as claimed.
    • Key Aspects: Petitioner asserted that Bruning’s disclosure of user control over voltage via the duty cycle of switch Q1 directly anticipates the core functionality of the independent claims, and its disclosure of independent control over different colored LED sub-arrays anticipates dependent claims related to changing light output.

Ground 2: Obviousness over Bruning in view of Kabel - Claims 1-3, 5, 7-10, 12, 14-17, and 19 are obvious over Bruning in view of Kabel.

  • Prior Art Relied Upon: Bruning (Application # 2002/0070914) and Kabel (Application # 2004/0164948).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to anticipation, particularly addressing the Patent Owner's potentially narrow construction of "switch." Petitioner argued that even if Bruning’s "panel light setting" was not itself a sufficient "switch," a person of ordinary skill in the art (POSITA) would have been motivated to implement it using the "manually-activatable slider bar" taught by Kabel.
    • Motivation to Combine: Petitioner asserted that Bruning and Kabel are analogous art, both directed to controlling LED backlights for LCD displays. A POSITA reading Bruning's disclosure of a user-controlled "panel light setting" without specific implementation details would have naturally looked to conventional solutions in the art, such as the user interface slider bar explicitly taught by Kabel for adjusting backlight brightness. The high degree of similarity between the systems' goals and components provided a strong motivation to combine their teachings.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination, as it involved applying a well-known, conventional user interface (a slider bar) to a known type of control circuit to achieve the predictable result of user-adjustable brightness.

Ground 3: Obviousness over Dowling in view of Mueller - Claims 1-2, 5, 7-9, 12, 14-16, and 19 are obvious over Dowling in view of Mueller.

  • Prior Art Relied Upon: Dowling (Application # 2002/0048169) and Mueller (Patent 6,016,038).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Dowling discloses a multi-colored LED lighting device with a user-operable "two-way switch" for selecting different color-changing modes, meeting the core limitations of independent claim 1. While Dowling teaches the concept, Mueller provides the necessary enabling details for the LED circuit structure and power supply. The combination of Dowling’s high-level system with Mueller’s specific circuit implementations allegedly rendered the claims obvious.
    • Motivation to Combine: The primary motivation was Dowling's express incorporation of Mueller by reference, stating that Mueller’s drive circuitry and color-mixing techniques should be used. Furthermore, Dowling's disclosure of its power converter was limited, motivating a POSITA to consult a reference like Mueller for known techniques to implement the required AC-to-DC power conversion using a transformer and bridge rectifier. The references also originated from the same assignee and shared common inventors.
    • Expectation of Success: A POSITA would have had a high expectation of success because the primary reference (Dowling) explicitly directed them to use the teachings of the secondary reference (Mueller). Combining Mueller's fundamental power supply and LED array designs with Dowling's control system was a predictable integration of compatible technologies.

  • Additional Grounds: Petitioner asserted that claims 3, 4, 10-11, and 17-18 are invalid under 35 U.S.C. §112 for indefiniteness and lack of written description, arguing the claim language was nonsensical or described impossible subject matter under the proper claim construction.

4. Key Claim Construction Positions

  • "forward voltage": Petitioner argued this term should be construed as "the minimum voltage difference required between the anode and cathode of the LEDs in the claimed circuit to allow current to flow through the LEDs." This construction was based on an express definition provided by the patentee during prosecution of a parent application. Petitioner used this construction to argue that claims requiring a switch to provide "at least two different DC forward voltages" to a single LED circuit were invalid under §112 as describing an impossibility, since a given circuit has only one such minimum voltage.
  • "switch": Petitioner contended the term "switch" should be given its plain and ordinary meaning. It argued against the Patent Owner's narrower construction requiring the switch to be physically configurable by an "end user." Petitioner pointed to disclosures in the ’341 patent suggesting the switch could be used by a manufacturer or assembler during the packaging process, not just an end user of the final product.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under the Fintiv factors would be inappropriate. The core arguments were that the parallel district court litigation was in its early stages, with no claim construction order, dispositive motions, or expert discovery completed. The scheduled trial date was over a year away and designated as "tentative," making it likely to be postponed. To further mitigate concerns of inefficiency and overlap, Petitioner stipulated that, if the Post Grant Review (PGR) was instituted, it would not pursue in the district court any ground that was instituted in the PGR.

6. Relief Requested

  • Petitioner requests institution of a PGR and cancellation of claims 1-5, 7-12, and 14-19 of the ’341 patent as unpatentable.