Trials@uspto.gov
`571-272-7822
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` Paper 39
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` Date: March 17, 2020
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`QUALCOMM, INC.,
`Patent Owner.
`_______________
`
`IPR2018-01283
`Patent 7,834,591 B2
`
`____________
`
`
`Before TREVOR M. JEFFERSON, DANIEL J. GALLIGAN, and
`SCOTT B. HOWARD, Administrative Patent Judges.
`
`JEFFERSON, Administrative Patent Judge.
`
`
`JUDGMENT
`Final Written Decision
`Determining All Challenged Claims Unpatentable
`Denying Patent Owner’s Motion to Exclude
`35 U.S.C. § 318(a)
`
`
`
`
`
`

`

`IPR2018-01283
`Patent 7,834,591 B2
`
`I.
`INTRODUCTION
`In this inter partes review, Apple Inc. (“Petitioner”) challenges claims
`1, 2, 4, 6–9, 11, 13–16, 18–21, 23–28, 30–37, 39, 42, 43, and 45 of U.S.
`Patent No. 7,834,591 B2 (“the ’591 patent,” Ex. 1001) which is assigned to
`Qualcomm Incorporated (“Patent Owner”). Paper 2 (“Petition” or “Pet.”).
`We have jurisdiction under 35 U.S.C. § 6. This Final Written
`Decision, issued pursuant to 35 U.S.C. § 318(a), addresses issues and
`arguments raised during the trial in this inter partes reviews. For the reasons
`discussed below, we determine that Petitioner has demonstrated the
`unpatentability of claims 1, 2, 4, 6–9, 11, 13–16, 18–21, 23–28, 30–37, 39,
`42, 43, and 45.
`
`A. Procedural History
`Petitioner filed a Petition challenging claims 1, 2, 4, 6–9, 11, 13–16,
`18–21, 23–28, 30–37, 39, 42, 43, and 45 of the ’591 patent (Pet. 2–3), and
`Patent Owner filed a Preliminary Response (Paper 6). We instituted trial on
`all grounds of unpatentability. Paper 7 (“Dec. on Inst.”), 22. During trial,
`Patent Owner filed a Response (Paper 20, “PO Resp.”), Petitioner filed a
`Reply (Paper 24, “Pet. Reply”), and Patent Owner filed a Sur-reply (Paper
`31, “PO Sur-reply”). Patent Owner filed a Motion to Exclude (Paper 32),
`Petitioner filed an opposition (Paper 33) to which Patent Owner replied
`(Paper 35). A combined oral hearing for this inter partes review and
`IPR2019-01452 was held on December 13, 2019, a transcript of which
`appears in the record in each case. Paper 38.
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`IPR2018-01283
`Patent 7,834,591 B2
`B. Instituted Grounds of Unpatentability
`We instituted inter partes review of claims 1, 2, 4, 6–9, 11, 13–16,
`18–21, 23–28, 30–37, 39, 42, 43, and 45 of the ’591 patent in on the
`following grounds:
`Claim(s) Challenged
`1, 2, 4, 7, 8, 11, 15, 16,
`18–21, 23–28, 30–37,
`39, 42, 43, 45
`6, 9
`
`35 U.S.C. §
`103(a)1
`
`References
`Bell,2 Kester,3 Martin4
`
`103(a)
`
`4, 13
`
`14
`
`103(a)
`
`103(a)
`
`Bell, Kester, Sherman,5
`optionally Martin
`Bell, Kester, Hatular,6
`optionally Martin
`Bell, Kester, Hatular,
`Sherman, optionally Martin
`
`Dec. on Inst. 6–7, 21–22; see Pet. 2–3.
`Petitioner relies on the Declaration of Dr. Joshua Phinney (Ex. 1003)
`and the Supplemental Declaration of Dr. Joshua Phinney (Ex. 1056). Patent
`Owner relies on the Declaration of Pradeep Lall, Ph.D. (Ex. 2007).
`
`
`1 The Leahy-Smith America Invents Act (“AIA”) included revisions to
`35 U.S.C. §§ 102, 103 that became effective on March 16, 2013. Because
`the ’558 patent issued from an application filed before March 16, 2013, we
`apply the pre-AIA versions of the statutory bases for unpatentability.
`2 U.S. Patent No. 5,723,970, issued March 3, 1998 (Ex. 1005, “Bell”).
`3 Walt Kester, Ed., PRACTICAL DESIGN TECHNIQUES FOR POWER AND
`THERMAL MANAGEMENT, Analog Devices, 1998 (Ex. 1007, “Kester”).
`4 U.S. Patent Application Publication No. 2007/0029975 A1, published Feb.
`8, 2007 (Ex. 1006, “Martin”).
`5 U.S. Patent No. 6,507,172 B2, issued Jan. 14, 2003 (Ex. 1012, “Sherman”).
`6 U.S. Patent No. 6,184,660 B1, issued Feb. 6, 2001 (Ex. 1021, “Hatular”).
`
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`Patent 7,834,591 B2
`
`C. Related Proceedings
`The parties inform us that the ’591 patent was asserted against
`Petitioner in the proceeding Qualcomm Inc. v. Apple Inc., Case No. 3:17-cv-
`2402 (S.D. Cal.), which has since been dismissed. Pet. 99; Paper 4, 1
`(Patent Owner’s Mandatory Notices); Paper 18, 1 (Petitioner’s Updated
`Mandatory Notices). Various claims of the ’591 patent also are at issue in
`related inter partes review IPR2018-01452. Pet. 99; see also Paper 4, 1.
`
`D. The ’591 Patent and Illustrative Claims
`The ’591 patent is titled, “Switching Battery Charging Systems and
`Methods” and discloses “[t]echniques for charging a battery using a
`switching regulator.” Ex. 1001, codes (54), (57). The ’591 patent discloses
`that “embodiments [of the invention] include switching battery chargers that
`modify the battery current based on sensed circuit conditions such as battery
`voltage or input current to the switching regulator.” Id. at 1:67–2:3. The
`’591 patent discloses that
`[i]n one embodiment, the present invention includes a Universal
`Serial Bus (USB) battery charger comprising a switching
`regulator having at least one switching transistor, the switching
`transistor having first input and a first output, wherein the first
`input of the switching transistor is coupled to a USB power
`source, a filter having a first input and a first output, wherein the
`first input of the filter is coupled to the first output of the
`switching transistor, and a battery coupled to the first output of
`the filter, wherein the switching regulator is configured to receive
`a USB voltage, and in accordance therewith, generate a
`switching signal to the control terminal of the switching
`transistor, and wherein a switching current and switching voltage
`at the output of the switching transistor are coupled through the
`filter to generate a filtered current and a filtered voltage to charge
`the battery.
`Id. at 2:4–18.
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`IPR2018-01283
`Patent 7,834,591 B2
`Figure 10A of the ’591 patent, shown below, illustrates charging a
`battery using a switching regulator in accordance with an embodiment of the
`invention. Id. at 18:64–66.
`
`
`
`Figure 10A of the ’591 patent shows current on the right vertical axis
`(“Current (A)”) and voltage on the battery on the left vertical axis (“Battery
`Voltage (V)”) versus time. Id. at 18:66–19:1. Battery voltage is shown by
`line 1001, current into the battery by line 1002, and current into the
`switching regulator by the line 1003. Id. at 19:1–4. The ’591 patent
`specifies two modes, current control mode and voltage control mode. Id. at
`19:6–7. Specifically, the ’591 patent describes that
`[t]his example [in Figure 10A] illustrates a charge cycle for
`charging a deeply depleted Li+ battery. The battery is charged
`in two basic modes: a current control mode (t=0, t2) and a voltage
`control mode (t=t2, t3). In this example, the voltage on the
`battery is initially below some particular threshold (e.g., 3 volts),
`indicating that the battery is deeply depleted. Accordingly, the
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`Patent 7,834,591 B2
`current control mode may initially generate a constant precharge
`current 1010 (e.g., 100 mA). The constant precharge current
`1010 will cause the battery voltage to start to increase. When the
`battery voltage increases above a precharge threshold 1020 (e.g.,
`3 volts), the system will increase the current sourced to the
`battery. The second current is sometimes referred to as the “fast
`charge” current.
`Id. at 19:4–17. The ’591 patent discloses that Figure 10A shows “the current
`into the battery may be larger than the current received by the switching
`regulator” and that “[a]s the battery voltage increases [during the charge
`process], the current into the battery may be reduced so that the input current
`remains approximately constant.” Id. at 19:18–26. Thus, the ’591 patent
`discloses, “if the voltage on the battery increases, and if the current supplied
`by the switching regulator remains constant, the current into the switching
`regulator will begin to increase.” Id. at 19:26–28.
`Claims 1, 8, and 32 are independent claims. Claim 1 (an apparatus)
`and claim 8 (a method) are illustrative and reproduced below (Ex. 1001,
`25:41–61, 26:25–39 (bracketed lettering added)).
`1.
`[a] A Universal Serial Bus (USB) battery charger
`comprising:
`[b] a switching regulator having at least one
`switching transistor, the switching transistor having a first
`input and a first output, wherein the first input of the
`switching transistor is coupled to a USB power source; and
`[c] a filter having a first input and a first output,
`wherein the first input of the filter is coupled to the first
`output of the switching transistor;
`[d] wherein the switching regulator is configured to
`receive a USB voltage, and generate a switching signal to
`a control terminal of the switching transistor, and
`[e] wherein a switching current and a switching voltage at
`the output of the switching transistor are coupled through
`the filter to a battery to generate a filtered current and a
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`IPR2018-01283
`Patent 7,834,591 B2
`filtered voltage to charge the battery, wherein the battery
`is coupled to the first output of the filter,
`[f] wherein the filtered current is greater than a first
`input current into the first input of the switching transistor,
`and [g] the filtered current is reduced, in a current control
`mode, as a voltage on the battery increases.
`
`[a] A method of charging a battery from a Universal
`8.
`Serial Bus (USB) port comprising:
`[b] receiving a first input voltage and a first input
`current at an input of a switching regulator from a USB
`power source;
`[c] coupling a switching output voltage and current
`from the switching regulator through a filter to a terminal
`of a battery; and
`
`[d] generating a first output voltage and a first
`output current at the terminal of the battery;
`[e] wherein the first input voltage is greater than the
`first output voltage on the battery, [f] the first output
`current to the battery is greater than the first input current,
`and [g] wherein the first output current is reduced, in a
`current control mode, as the first output voltage on the
`battery increases.
`Ex. 1001, 25:41–61, 26:25–39.
`
`II. ANALYSIS
`
`A. Level of Ordinary Skill in the Art
`The Petition states that the person of ordinary skill in the art related to
`the ’591 patent at the time of filing “would have had at least a Bachelor’s
`Degree in Electrical Engineering and at least five years of experience in the
`field of power electronics. Additional education can compensate for less
`work experience, and vice versa.” Pet. 4 (citing Ex. 1003 ¶ 18).
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`Patent 7,834,591 B2
`Patent Owner asserts that:
`A person of ordinary skill in the art (a “POSITA”) relevant to the
`’591 Patent at the time of its invention would have had (a) a
`Bachelor’s of science degree in an engineering discipline or
`physics, or a closely-related field, and at least two years of work
`or research experience in the field of circuit design, or (b) a
`Master’s of science degree in an engineering discipline or
`physics, or a closely-related field, and at least one year of work
`or research experience in that same field. EX2007, ¶32. More
`work experience could compensate for less education, and vice
`versa. Id.
`PO Resp. 4.
`The parties do not materially dispute the level of ordinary skill in the
`art, differing in relevant experience and the types of technical degrees. See
`PO Resp. 4; Ex. 1003 ¶ 18. Our Institution Decision adopted Petitioner’s
`proposed level of skill in the art with the exception of the “at least”
`qualification. Dec. on Inst. 11. Neither party indicates whether the
`differences in level of skill affects their prior art contentions.
`On the full record, we adopt Petitioner’s definition of the level of
`ordinary skill in the art with the exception of the “at least” qualification,
`because it is commensurate with the level of skill reflected in the ’591 patent
`and prior art references of record. See In re GPAC Inc., 57 F.3d 1573, 1579
`(Fed. Cir. 1995).
`
`B. Claim Interpretation
`In an inter partes review for a petition filed before November 13,
`2018, a claim in an unexpired patent shall be given its broadest reasonable
`construction in light of the specification of the patent in which it appears.
`37 C.F.R. § 42.100(b) (2018); see Changes to the Claim Construction
`Standard for Interpreting Claims in Trial Proceedings Before the Patent Trial
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`and Appeal Board, 83 Fed. Reg. 51,340 (Oct. 11, 2018) (amending
`37 C.F.R. § 42.100(b); effective November 13, 2018). The Petition was
`accorded a filing date of July 27, 2018, and therefore, the broadest
`reasonable interpretation standard for claim interpretation applies. See
`Paper 5 (Notice of Filing Date Accorded to Petition). In applying a broadest
`reasonable interpretation, claim terms generally are given their ordinary and
`customary meaning, as would have been understood by one of ordinary skill
`in the art in the context of the entire disclosure. See In re Translogic Tech.,
`Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). This presumption may be
`rebutted when a patentee, acting as a lexicographer, sets forth an alternate
`definition of a term in the specification with reasonable clarity,
`deliberateness, and precision. In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir.
`1994).
`
`1. “coupled to” and “coupled”
`Petitioner asserts proposed plain meaning constructions for “coupled
`to” (claims 1–7, 13–45) and “coupling” (claims 8–12, 25–31). Pet. 4–5.
`Patent Owner does not contest these constructions. See PO Resp. 16–19.
`Based on the full record, the terms “coupled to” and “coupling” are not in
`controversy and their plain meaning requires no further construction. See,
`e.g., Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d
`1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in
`controversy, and only to the extent necessary to resolve the controversy’ . . .
`.” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803
`(Fed. Cir. 1999))).
`
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`Patent 7,834,591 B2
`2. Means-Plus-Function Limitations (claims 35 and 44).
`Petitioner proposes claim constructions for two means-plus-function
`limitations terms governed by § 112 ¶ 6. Pet. 5–6. Petitioner asserts that
`“means for sensing the input current” as recited in claim 35, has a function
`of “sensing input current” and the corresponding structure is an “input sense
`resistor, a transistor, or an inductive sensor.” Pet. 5 (citing Ex. 1001, 21:2–
`5, 21:15–17; Ex. 1003 ¶ 21). Petitioner also argues that “means for sensing
`the output voltage on the battery” as recited in claim 44 has a function of
`“sensing output voltage on a battery” and the corresponding structure is a
`battery sense terminal, an input, or an analog-to digital circuit.” Pet. 5–6
`(citing Ex. 1001, 22:12–19, 23:17–18; Ex. 1003 ¶ 22). Patent Owner does
`not dispute Petitioner’s constructions. See generally PO Resp. 16–19.
`Patent Owner does not challenge or contest Petitioner’s identification
`of the limitations of claims as means-plus-function limitations nor the
`structures that perform the identified functions. Based on the full record, we
`agree with and adopt Petitioner’s identified functions and structures for the
`means-plus-function limitations of claims 35 and 44.
`3. “the filtered current is reduced, in a current control mode, as a
`voltage on the battery increases.” (claim 1[g]);
`“wherein the first output current is reduced, in a current control mode,
`as the first output voltage on the battery increases” (claim 8[g]);
`“wherein, during at least a portion of the current control mode, . . . the
`current controller reduces the output current to the battery as the voltage
`on the battery increases” (claim 32[i])
`Patent Owner contends that the limitations in 1[g] and 32[i] “as the
`voltage on the battery increases” should be construed as “in response to a
`sensed increase in battery voltage”; and that “as the first output voltage on
`the battery increases” as recited in claim limitation 8[g] should be construed
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`Patent 7,834,591 B2
`as “in response to a sensed increase on the first output voltage.” PO Resp.
`19.7
`
`Patent Owner argues that under the broadest reasonable interpretation:
`a POSITA would understand “as a voltage on the battery
`increases” in the claims of the ’591 Patent to mean “in response
`to a sensed increase in battery voltage.” See EX2007, ¶58. The
`’591 Patent discloses “switching battery chargers that modify the
`battery current based on sensed circuit conditions such as
`battery voltage or input current to the switching regulator.”
`APPLE-1001, 1:67–2:3; see also EX2007, ¶60; APPLE-1001,
`2:46–50; 2:57–67; 3:8–12; 3:46–50; 5:23–30; 5:63–67; 6:11–14;
`11:11–16; 17:14–16; 17:26–31; 18:22–25; 18:36–39; 18:59–63.
`In describing Figure 10A, the ’591 Patent explains that the
`depicted charging profile occurs in response to sensing “either
`input current to the switching regulator or battery voltage.” See
`EX1001, 19:45–47; see also EX2007, ¶¶43–44. Claim elements
`[1g], [8g], and [32i] each claim an embodiment where battery
`current is modified based on the sensed battery voltage.
`PO Resp. 17. Patent Owner asserts that “[a]ny alternative construction of
`“as a voltage on the battery increases,” that relies on natural decreases in a
`current control mode” “renders the “as a battery voltage increases” language
`superfluous. PO Resp. 18 (citing Ex. 2007 ¶ 63).
`Petitioner contends that neither the ’591 Specification nor the plain
`language of claims support Patent Owner’s proposed construction. Pet.
`Reply 1–10. Specifically, Petitioner argues the Specification describes
`alternatives for reducing charging current as voltage on the battery increases,
`one based on sensed battery voltage and the other based on sensed current
`
`
`7 The ’591 patent describes charging current as “filtered current” (claim 1),
`“first output current” (claim 8), or “output current” (claim 32). Neither party
`has identified any difference among these terms with respect to the
`“charging current” at issue.
`
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`Patent 7,834,591 B2
`voltage. Pet. Reply 3 (citing Ex.1001, 17:26–33 (describing the two
`embodiments), 19:23–47 (same); 18:14–16 (describing alternative
`embodiments); 18:22–29 (describing Sensed Input Current embodiment);
`20:25–30 (describing each embodiment, in turn)). Petitioner argues that
`Patent Owner’s proposed construction would import a limitation from the
`Specification and limit the challenged claims to the sensed battery voltage
`embodiment, and exclude the sensed current embodiment. See Pet. Reply 4
`(citing SuperGuide Corp. v. DirecTV Enters., Inc., 358 F.3d 870, 875 (Fed.
`Cir. 2004); Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898, 913 (Fed.
`Cir. 2004); Hyperphrase Techs., LLC v. Google, Inc., 260 F. App’x 274, 280
`(Fed. Cir. 2007); Anchor Wall Sys., Inc. v. Rockwood Retaining Walls, Inc.,
`340 F.3d 1298, 1308 (Fed. Cir. 2003)).
`Petitioner asserts that the “as” a voltage or first out voltage increase is
`not superfluous because the plain language adds a temporal requirement,
`confines the current reductions magnitude, limits the type of battery
`charging, and introduces the requirement that the battery be charging. Pet.
`Reply 3–8. Petitioner argues that Patent Owner cites no basis or evidence
`that a person of ordinary skill in the art under the broadest reasonable
`interpretation would have understood the “as” voltage increases limitations
`to be superfluous absent a direct sensed voltage.
`Finally, Petitioner argues that claim differentiation between
`independent claim 32 and dependent claim 44, which introduces a “means
`for sensing the output voltage on the battery to control the output current to
`the battery to reduce as the voltage on the battery increases,” (Ex.1001, cl.
`44) adds the express requirement of sensing battery voltage indicating that it
`is not already so narrowed in independent claim 32. Pet. Reply 8–9; Karlin
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`Techs, Inc. v. Surgical Dynamics, Inc., 177 F.3d 968, 971-72 (Fed. Cir.
`1999) (Claim differentiation “normally means that limitations stated in
`dependent claims are not to be read into the independent claim from which
`they depend”). Similarly, Petitioner describes that other dependent claims
`incorporate the sensed current embodiment based on current. Pet. Reply 9–
`10 (citing Ex. 1001, claims 27, 35, 43).
`Based on the parties’ arguments and evidence, we agree with Patent
`Owner that the Specification teaches the broadest reasonable interpretation
`of the “as” voltage increases clauses of claims 1, 8, and 32 to be “in response
`to a sensed increase” in the battery voltage. See PO Resp. 17–19; see
`Tr. 23:23–24:4 (Patent Owner’s counsel agreeing that the there is a cause
`and effect relationship sensed between battery voltage increase and current).
`We also agree with Patent Owner that the ’591 patent discloses “switching
`battery chargers that modify the battery current based on sensed circuit
`conditions such as battery voltage or input current to the switching
`regulator.” Ex. 1001, 1:67–2:3 (emphasis added); see PO Sur-reply 2–3.
`Furthermore, the ’591 patent Specification teaches “the switching regulator
`may detect the rise in the battery voltage by sensing either the battery
`voltage directly, the input current, or other related parameters.” Ex.1001,
`18:61–63. Thus, the ’591 patent explains that indirect sensing methods by
`“other related parameters” fall within the scope of the claims.
`The plain language of the dependent claims also supports indirect
`sensing methods. We agree with Petitioner that dependent claim 44
`presumably narrows independent claim 32, requiring directly sensing the
`output voltage of the battery. Pet. Reply 8–9. Patent Owner’s argument that
`claim 44 merely adds the “means” for sensing the battery voltage does not
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`address persuasively the claim differentiation, supported by the ’591
`Specification (Ex. 1001, 18:61–63). See PO Sur-reply 3. We find that
`independent claim 32, like claims 1 and 8, is not limited to direct voltage
`measurements, as dependent claims 35 and 43 add direct sensing of input
`current to independent claim 32 (PO Sur-reply 3–4). These claims further
`support the broader scope of the independent claims, which are not limited
`to direct measurement of battery voltage.
`Accordingly, we agree with Patent Owner that the broadest reasonable
`construction of the plain language of the claim limitations 1[g] and 32[i]
`should be construed as “in response to a sensed increase in battery voltage”
`and that “as the first output voltage on the battery increases” as recited in
`claim limitation 8[g] should be construed as “in response to a sensed
`increase on the first output voltage.” PO Resp. 19. The “sensed increase,”
`however, is not limited to direct sensing, but may be indirect through “other
`related parameters” as the ’591 Specification teaches. Ex. 1001, 18:61–63.
`
`C. Principles of Law
`A patent claim is unpatentable under 35 U.S.C. § 103(a) if the
`differences between the claimed subject matter and the prior art are such that
`the subject matter, as a whole, would have been obvious at the time the
`invention was made to a person having ordinary skill in the art to which said
`subject matter pertains. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406
`(2007). The question of obviousness is resolved on the basis of underlying
`factual determinations including (1) the scope and content of the prior art;
`(2) any differences between the claimed subject matter and the prior art;
`(3) the level of ordinary skill in the art; and (4) any secondary
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`considerations, if in evidence.8 Graham v. John Deere Co., 383 U.S. 1, 17–
`18 (1966).
`
`D. Obviousness by Bell, Kester, and Martin
`(Claims 1, 2, 4, 7, 8, 11, 15, 16, 18–21, 23–28, 30–37, 39, 42, 43, 45)
`1. Overview of Bell (Ex. 1005)
`Bell is a patent titled “Battery Charging Circuitry Having Supply
`Current Regulation.” Ex. 1005, code (54). Bell discloses:
`A power supply is disclosed for use in battery powered
`electronic devices. The power supply includes a power source
`which supplies power to the electronic device itself as well as to
`battery charging circuitry integral to the power supply. The
`battery charging circuitry monitors an output current, or other
`parameter, of the power source output. Feedback circuitry
`regulates the output of the battery charging circuitry so that
`output current, or other parameter of the power source output, is
`kept within predetermined limits.
`Id. at code (57). Bell provides a block diagram for a power supply and
`schematic circuit diagrams for a battery charger. Id. at Figs. 1, 4A, and 4B.
`Figure 1, below, shows a block diagram of Bell’s power supply circuitry.
`
`
`
`
`8 Patent Owner does not present any objective evidence of nonobviousness
`(i.e., secondary considerations) as to any of the challenged claims.
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`Figure 1 above shows battery charger 20 to charge battery 14 and
`system DC/DC converter 12 to provide power to device circuitry. Id. at
`3:31–42. Battery charger 20 includes a feedback control loop, which varies
`the charging rate of the battery during a charge to limit the current drawn
`from power converter 19. Id. at 3:1–4. Figure 3 of Bell, shown below,
`provides a block diagram of the power supply circuitry. Id. at 3:3:22–25
`
`
`Bell’s battery charger 20 in Figure 1 includes “switching DC/DC converter”
`32 shown in Figure 3 that provides power to the battery. Id., 6:55–61.
`Separate system DC/DC converter 12 provides power. Id. at 6:55–61, Fig. 3
`(showing two DC/DC converters, 32 and 12). Bell identifies the switching
`DC/DC converter used for battery charging as a “Buck” stepdown converter.
`Id. at 6:60–61.
`The battery charger circuit 20 in Figure 1, is shown in Figure 4A
`below.
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`
`
`Figure 4A above shows integrated circuit 70 with “a conventional current-
`mode switching DC/DC converter” that includes DC/DC converter, shown
`in further detail in Figure 4B below. Id. at 6:55–57.
`
`
`Figure 4B above shows more detail for integrated circuit 70 of Figure 4A,
`including switch circuitry 76. Ex. 1005, 6:52–58. Bell discloses that
`circuit 70 employs three feedback loops: output current feedback loop (id. at
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`6:64–7:4); output voltage feedback loop (id. at 8:2–21); and input current
`“third” feedback loop (id. at 8:22–42).
`2. Overview of Kester (Ex. 1007)
`Kester, which is titled “Practical Design Techniques for Power and
`Thermal Management” by Analog Devices, is a book that describes theory
`and applications in power management. See generally Ex. 1007. Section 3
`of Kester discloses an overview of the voltage and current relationships in
`conventional switching power converters, including a Buck regulator.
`Ex. 1007, 9–79 (Section 3). Kester explains that Buck regulators step down
`voltage and increase current so that “the input current is lower than the
`output current.” Ex. 1007, 3.3.
`3. Overview of Martin (Ex. 1006)
`Martin is a U.S. patent application titled, “Power Manager and Power
`Managing Method of Battery-Powered Application.” Ex. 1006, code (54).
`Martin discloses a power manager for “controlling power delivery to a load
`and a battery from a power source.” Id. ¶ 1. Martin teaches that a “USB
`itself can be used to directly power [portable] devices and charge [their]
`batteries” when current from the USB source is regulated. Id. ¶ 2.
`4. Claim Analysis
`Petitioner argues that Bell, Kester, and Martin teach the limitations of
`claims 1, 2, 4, 7, 8, 11, 15, 16, 18–21, 23–28, 30–37, 39, 42, 43, and 45 of
`the ’591 patent. Pet. 23–79. Petitioner argues that combining Bell and
`Kester with Martin would have been obvious to further Bell’s goal of
`efficient and convenient battery charging. Pet. 13–15. Petitioner argues that
`the combination of Bell and Martin teach MOS transistors and that such
`transistors could be used in place of diodes in the transistor shown in Bell.
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`Pet. 16; Ex. 1003 ¶¶ 176–178. Petitioner further asserts that a person of
`ordinary skill in the art would have known that USB specifications limit
`input current (Ex. 1003 ¶ 164) and that Bell’s circuitry could be configured
`to comply with USB limits (Ex. 1003 ¶¶ 164–175). Pet. 17–20. Finally,
`Petitioner argues that Kester teaches the basic operating principles of the
`Buck regulator used in Bell. Pet. 21; Ex. 1003 ¶¶ 147–153.
`Petitioner asserts that a person of skill in the art would have combined
`Bell, Kester, and Martin to use the USB power source and produced a
`smaller and lighter external power supply. Pet. 21–22; Ex. 1005, 2:48–54.
`Petitioner argues that “modification of Bell” involves “the use of known
`techniques, e.g., using USB power for battery charging, setting USB input
`current limits, using a MOSFET as a switching transistor, and using Li-ion
`batteries (as known to a POSITA) to improve similar devices (e.g., the
`battery charging circuitry of Bell) in the same way.” Pet. 22 (citing KSR,
`550 U.S. at 417; Ex. 1003 ¶ 157).
`Petitioner provides persuasive evidence and argument mapping the
`Bell, Martin, and Kester combination to the limitations of independent
`claims 1, 8, and 32. Pet. 23–52; Ex. 1003 ¶¶ 194–286. With respect to
`independent claims 1 and 8, Petitioner provides detailed analysis showing
`where Bell, Kester, and Martin in combination teach [1a]–[1f] and [8a]–[8e]
`of claims 1 and 8. Pet. 23–37. Petitioner also provides detailed argument
`and evidence to support its contentions that the Bell-Martin-Kester
`combination teaches the limitations of claims 1, 8, and 32. Pet. 23–52.
`With respect to claims 1 and 8, Petitioner asserts that the combination
`of Bell, Martin, and Kester teaches the USB battery charger or port
`limitations 1[a] and 8[a]. Pet. 23–24. With respect to limitation 1[b] and
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`8[b], Petitioner argues that Bell teaches switch circuitry and Martin teaches
`the p-type MOS power switch transistor for the switching regulator
`limitations. Pet. 24–27.
`For limitation 1[c], Petitioner asserts that Bell’s charging circuit
`includes filter circuitry. Id. at 27–28. Petitioner also argues that the
`switching regulator that generates a switching signal as required in limitation
`1[d] is taught by the combination of Bell and Martin. Id. at 29–31. For
`limitations 1[e], 8[c], and 8[d], Petitioner contends that coupling a switching
`current and voltage through a filter to a battery for charging are taught by
`Bell, Martin, and Kester. Id. at 31–34.
`Petitioner asserts that limitations 1[f] and 8[f], which require that the
`filtered current is greater than the input current, is not expressly taught by
`Bell, but it would have been understood by an ordinarily skilled artisan in
`view of Kester, because Bell’s switching regulator under common operating
`conditions would produce filtered current that is greater than the input
`current. Id. at 35; Ex. 1003 ¶¶ 218–223, 257–259. Petitioner states that:
`The type of switching regulator in Bell’s Fig. 4A is “a
`‘Buck’ step-down DC/DC power converter.” APPLE-1005,
`6:55-61. Kester explains that Buck regulators were known to
`provide output current greater than input current. APPLE-1007,
`3.3 (“in stepdown (buck) designs, the input current is lower than
`the output current”), 3.11 (“average input current is less than the
`average output current”). Thus, in the combination, Bell’s
`switching regulator 11 would provide filtered output current
`(e.g., current at the node where the positive terminal of capacitor
`142 connects) that is greater than the input current (e.g., current
`entering the VCC pin that connects to the switching transistor),
`since this is common, well-known behavior of a Buck regulator.
`APPLE-1003, [0218]-[0223] and [0257]-[0259].
`Pet. 36.
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`For the claim 8[e] limitation that the first input voltage is greater than
`the first output voltage on the