• Feit Electric Company, Inc. v. Signify Holding B.V. F/K/A Philips Lighting Holding B.V.Some claims unpatentable
  PTAB · Oct 18, 2019 · IPR2018-00921 · APJ Jason M Repko · IPR · Final written decision

  Claims 1, 22, and 30 are unpatentable as obvious over Biebl; claims 7 and 14 were not shown unpatentable because the proposed combinations lacked sufficient support.

  RulingsFinal written decision

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner

    “The Specification supports the construction that an oscillating signal is periodically varying. For instance, the Specification states that “the low frequency oscillating signal changes from low to high.” Ex. 1001, 2:35–37. In another example, “the oscillating signal can be a square wave oscillating between 0 and 16 volts with a frequency of 200 to 300 Hertz.” Id. at 4:17– 20. In these examples, the ’890 patent uses term “oscillating” to describe signals having periodic variation or change. Thus, we construe “an oscillating signal” as a signal with periodic variation. generating an oscillating signal. Petitioner’s definition from a technical dictionary merely adds that an oscillator is (1) an electronic circuit and (2) “converts energy from a direct-current source.” Pet. Reply 4 (citing Ex. 1021, 3 (McGraw-Hill Dictionary of Scientific and Technical Terms 1341–40 (4th ed. 1989))). There is no dispute about a direct-current source. The Specification discusses an “oscillator” in terms of its function. See Ex. 1001, 2:17–19, 26–27; 44–48. Thus, we determine that “oscillator” means an electronic circuit that generates an oscillating signal.” slip op. at 7

  • Claim Construction › Functional claiming / §112(f) means-plus-function › Corresponding structure / algorithm (indefinite if none)Term construed board ownDecided for patent owner

    “We agree with Patent Owner that the Patent indicates that either set of resistors can perform the claimed function. Prelim. Resp. 12. For instance, R1A1, R1A2, and R1A3 appear in the schematic diagram in Figure 2A. This diagram shows a first power supply 112 that supplies current to LED array 114. Ex. 1001, 3:11–12. LED array 114 responds to signals for the STOP input 104 or TURN input 102. Id. at 3:12–14. The resistors are between the first power supply 112 and LED array 114 to sense current. Id. at 3:31–35. By contrast, R1B1, R1B2, and R1B3 appear in the schematic diagram in Figure 2C. This diagram shows a second power supply (130) that supplies power to LED array 126. Id. at 3:55–56. LED array 126 responds to signals for the STOP input 104 or TAIL input 106, depending on the input mode. Id. at 3:56–59. Figure 2C shows the resistors connected to the second power supply 130. Id., Fig. 2C. So the two sets of resistors perform the same function but are connected to different power supplies. Thus, the structures disclosed in the Specification as corresponding to the claimed function are (1) R1A1, R1A2, or R1A3 or (2) R1B1, R1B2, or corresponding structure because it is immaterial to our analysis below.” slip op. at 10

  • Skill levelSkill level petitioner adoptedDecided for petitioner

    “Any difference between Petitioner’s and Patent Owner’s proposed levels of ordinary skill in the art are immaterial because, as Dr. Zane explains, “applying Dr. Shackle’s standard for the level of ordinary skill in the art would not affect [Dr. Zane’s] analysis and conclusion regarding the patentability of any challenged claim.” Id. ¶ 27. So we apply Petitioner’s proposed definition, which appears to be consistent with the level of skill reflected in the asserted references. See Okajima v. Bordeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (explaining that the prior art itself can reflect an appropriate level of skill in the art).” slip op. at 22

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable

    “Yet nothing in the claim suggests that visual characteristics are relevant. Rather, claim 1’s system uses the recited states for a purpose unrelated to viewing waveforms—i.e., to determine whether to supply power or not. See Ex. 1001, 5:24–27. So we are unpersuaded by Patent Owner’s argument that slope or other visual characteristics should be the only basis for defining the states. See PO Resp. 15. Thus, Petitioner has shown that Biebl teaches “an oscillating signal having a first state and a second state.”” slip op. at 26

  Patent outcomesUS 6,586,890 mixed
  Claim construction§ 103 obviousness
  Patents in suitUS 6,586,890

Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.