- Home Depot USA, Inc. v. Lynk Labs, Inc.Some claims unpatentablePTAB · May 5, 2023 · IPR2022-00023 · APJ Arthur M Peslak · IPR · Final written decision
Claims 1 and 4 are unpatentable over the stated § 103 combinations; Petitioner did not show claim 2 unpatentable because it did not explain how the LED array’s forward voltage is received by the driver.
RulingsFinal written decision- Skill levelSkill level board ownOther
“degree in electrical engineering, or similar technical field, with two years of experience in the field of design and/or development of light-emitting diodes (LEDs) and circuits in the context of lighting control systems.” Pet. 11–12 (citing Ex. 1002 ¶ 34). Petitioner further contends that “[a]n increase in experience could compensate for less education.” Id. at 12. Patent Owner proposes the same level of skill in the art. See PO Resp. 6. We apply the parties’ undisputed level of ordinary skill in the art because it comports with the level of skill reflected in the ’149 patent and the prior art of record.” slip op. at 8
- Expert testimonyPetitioner expert creditedDecided for petitioner
“We credit Dr. Lebby’s testimony over Dr. Ducharme for the following reasons. First, in Deese, power cable 28 is inserted into an opening in rubber housing 21. Ex. 1008, Fig. 2A. [R]ubber housing 21 forms a water-tight seal around the power cable 28.” Id. at 4:63–65. Dr. Ducharme does not explain why Hochstein’s protruding heat sink shell could not similarly be inserted through rubber housing 21 with a water-tight seal. Further, Dr. Lebby relies on the similarity between the structures of Deese and Hochstein. Hochstein uses gasket 45 and weather seal 48 to seal housing 10 with electrical lead 49 and heat sink shell 38 extending therethrough. Ex. 1010, 5: 39–40, 5:63:65, Fig. 8.” slip op. at 47
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed patent owner constructionOther
“Our analysis starts with the claim language. Claim 1 recites “a driver, wherein the driver includes at least one transistor and at least one capacitor” and “the driver is configured to receive an AC voltage from a mains power source and provide a voltage and current to the at least one LED circuit.” Ex. 1001, 23:16–17, 26:22–24. Dr. Ducharme testifies that power is determined by multiplying voltage and current. Ex. 2008 ¶ 63. The language of claim 1, thus, supports Patent Owner’s construction which is also consistent with the dictionary definition offered by Petitioner which also defines “driver” as [a] program, circuit or device used to power or control other programs, circuits or devices.” Ex. 1007, 4 (emphasis added). The Specification provides “the driver providing an AC voltage and current to one or more LED circuits.” Ex. 1001, 3:65–67. Thus, the Specification also provides support for Patent Owner’s construction. For the foregoing reasons, we apply Patent Owner’s proposed construction of “driver” because it is consistent with the language of claim 1 and the description of driver in the Specification. We note that the adjective “LED” prior to circuits or devices in Patent Owner’s construction is not necessary because that it essentially repeats limitation 1.e.” slip op. at 12
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITADecided for petitioner
“We begin with the claim language itself which is “the package is a heat sinking reflective material.” Ex. 1001, 23:18–19 (emphasis added). In its analysis, Patent Owner parses “heat sinking reflective material” out of context by omitting the italicized language “the package is” preceding “heat sinking reflective material.” PO Resp. 29. The deposition testimony of Dr. Lebby and Dr. Ducharme’s declaration testimony cited by Patent Owner are also out of context. The Specification of the ’149 patent defines “package” as an integrated unit that “in certain applications may preferably include a heat sink, a reflective material, a lens for directing light, phosphor nano-crystals or light changing or enhancing substances.” Ex. 1001, 5:30–33. Because heat sink and reflective material are listed separately in the Specification, this disclosure suggests that, at least in certain embodiments, a package with a heat sink separate from a reflective material would fall within the scope of limitation 1.c. This is further confirmed by comparing the packages illustrated in Figures 25 and 26 of the ’149 patent which are reproduced above. Figure 25 is described as illustrating “heat sinking material 198 . . . integrated into the package 30.” Id. at 17:34–35. Figure 26 is described as illustrating reflector 202 “integrated into the package 30 for optimized light dispersion.” Id. at 17:47–49. As can be seen from a visual comparison of Figures 25 and 26, reflector 202 is separate from heat sinking material 198. Given the disclosure in the ’149 patent of a package with a heat sink” slip op. at 15
Patent outcomesUS 10,517,149 mixedClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,517,149 - Home Depot U.S.A., Inc. v. Lynk Labs, Inc.All claims unpatentablePTAB · Apr 26, 2023 · IPR2021-01541 · APJ Scott Raevsky · IPR · Final written decision
Claims 1–4, 6–8, 11–13, 15–17, and 19 are unpatentable as obvious over the cited combinations of Dowling, Mueller, Okuno, Nortrup, Yan, and Martin.
RulingsFinal written decision- BurdenFwd all claims unpatentableUnpatentable
“After considering the evidence and arguments of the parties, we determine that Petitioner has proven by a preponderance of the evidence that claims 1– 4, 6–8, 11–13, 15–17, and 19 are unpatentable.” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“understanding of a person of ordinary skill in the art at the time of the invention. Graham, 383 U.S. at 13, 17. Petitioner asserts that [a] person of ordinary skill in the art (“POSITA”) . . . would have had a bachelor’s degree in electrical engineering, or similar technical field, with two years of relevant experience in the field of design and/or development of LEDs and circuits in the context of lighting control systems. An increase in experience could compensate for less education. Pet. 10–11 (citing Ex. 1002 ¶ 22). Patent Owner does not dispute Petitioner’s definition of the level of ordinary skill. PO Resp. 14. We are persuaded that Petitioner’s proposal is consistent with the problems and solutions in the ’001 patent and prior art of record. We therefore adopt Petitioner’s definition of the level of skill.” slip op. at 6
- Expert testimonyPetitioner expert creditedDecided for petitioner
“Under the correct claim construction, Dowling discloses this limitation because Dowling discloses several examples of two-way switch 190 turning on or off LED circuits, independent of other LED circuits. For example, Dr. Neikirk persuasively testifies that Dowling’s color wash mode (selected by switch 190) discloses this limitation by referring to LEDs that “cycle . . . through the full color spectrum,” turning different colored LEDs on or off. Ex. 1033 ¶ 26 (citing Ex. 1004 ¶¶ 44, 103 (“If two LEDs were used . . . with circuitry to turn each color on or off, four colors could be produced.”) (emphasis added)). As another example, Dr. Neikirk persuasively testifies that switch 190 can be used to select a “static color mode to produce, for example, the color red, then only the red LED will be turned on and the remaining LEDs will be turned off.” Id. ¶ 28 (citing Ex. 1004 ¶ 103). Finally, Dr. Neikirk persuasively testifies that switch 190 can select a strobing mode to cause LEDs to “alternate[] green and red,” which a POSITA would have understood to cause “at least one color LED circuit to be turned on or off independent of other LED circuits.” Id. ¶ 29 (citing Ex. 1004 ¶ 47). Patent Owner does not rebut these assertions of Dr. Neikirk. See Sur- reply 7–10. Accordingly, we determine that Petitioner has established that Dowling discloses this limitation.” slip op. at 26
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for petitioner
“We begin our analysis with the claim language. Claim 1 requires a switch to “independently switch on or off at least one of the first LED circuit or the at least one additional LED circuit.” There is no express requirement in the claim that any switching occur independently “of other switches.” In effect, Patent Owner appears to imply that “independently” modifies only the word “switch.” Yet the plain reading of this phrase is that the word “independently” modifies the entire phrase that follows—“switch on or off at least one of the first LED circuit or the at least one additional LED circuit.” As such, the plain language of the claim encompasses switching one of the LED circuits on or off independently of another LED circuit. In other words, the switch can turn on or off either LED circuit by itself, without affecting the other LED circuit. Patent Owner even appears to have had the same understanding pre-institution, arguing that one of Dowling’s modes “is simultaneously controlling all the LEDs, not independently switching one LED circuit on or off.” Prelim. Resp. 19. The specification does not inform the meaning of this limitation because it does not include the word “independently”—this term only appears in the claims. And Patent Owner points us to no discussion of independent switching in the specification by another name. At most, Patent Owner refers to two separate claims and a few specification references that possibly mention two separate switches. Sur-reply 3–4. But Patent Owner’s references to claims 11 and 15 are unavailing, as even if claims 11 and 15 mention different switches, Patent Owner does not sufficiently explain how this compels the meaning it ascribes to “independently switch.” This is true even though claim 11 itself recites a similar “independently switch” limitation. Further, the specification’s mere mention of different switches is also insufficient to draw any conclusion about whether those switches are independently switched from one another. We therefore find no disavowal, lexicography, or any context that would counsel departing from the plain and ordinary meaning of this limitation. As such, we construe “a switch . . . configured to at least one of independently switch on or off at least one of the first LED circuit or the at least one additional LED circuit” in claims 1, 6, and 11 to encompass a switch that switches an LED circuit on or off independently of another LED circuit.” slip op. at 11
Patent outcomesUS 10,537,001 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,537,001 - Samsung Electronics Co., Ltd. v. Lynk Labs, Inc.Some claims unpatentablePTAB · Apr 19, 2023 · IPR2021-01576 · APJ Scott Raevsky · IPR · Final written decision
Claims 1–12 are unpatentable as obvious; claims 13–18 are not shown unpatentable because the asserted combinations fail to teach or suggest multiple LED packages connected in series.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“PO Resp. 8 (citing Ex. 2001 ¶¶ 41–42). Patent Owner argues that its definition is superior because Petitioner’s “and/or” qualifier “might be read as considering a person who has ‘related circuit design’ experience but no experience with ‘LED devices’ to be a POSITA.” Id. at 9. Patent Owner further views Petitioner’s “or a related field” phrasing as potentially including a person who has no experience with LED devices. Id. We agree with Patent Owner on both points. We agree with Patent Owner that Patent Owner’s proposal is more consistent with the problems and solutions in the ’979 patent and prior art of record. We adopt Patent Owner’s definition of the level of skill but note that had we adopted Petitioner’s level of skill, we would not have reached a different outcome here.” slip op. at 6
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed petitioner constructionDecided for petitioner
“specification support its construction of “formed or mounted to” as encompassing indirect attachment to the substrate. Neither the plain claim language nor the specification requires the phosphor coating to be directly attached to the substrate. Limitation 1(c) recites, wherein the LED chips comprise a phosphor coating to produce a change in a color or a quality of light emitted from the LED chips, wherein the LED chips, the power connection leads, and the phosphor coating are formed or mounted to a flexible substrate that is sufficiently flexible to be formed into a cylindrical shape[.] Ex. 1001, 22:7–12 (emphasis added). The claim is inartfully written, as it requires the LEDs to comprise a phosphor coating but then separately recites that the LED chips and the phosphor coating are formed or mounted to the substrate. But Petitioner correctly explains that the plain meaning requires that “the LED chips comprise a phosphor coating” and that “the [same] phosphor coating” (included in the LED chips) is “formed or mounted to a flexible substrate.” Reply 2. In other words, the use of the term “the” before “phosphor coating” indicates reliance on the antecedent basis of “LED chips comprise a phosphor coating,” and thus the same coating of the LED chips is formed or mounted to the substrate. Logically, by including a phosphor coating with the LED chips, which are formed or mounted to the substrate, the coating of these chips is also indirectly formed or mounted to the substrate. Conversely, it would be illogical to conclude that the claim recites two phosphor coatings, one attached to the LED chips and another attached directly to the substrate, because the structure of the claim refers to a single phosphor coating of the LED chips. Even Patent Owner concedes that the claim encompasses the phosphor coating indirectly being mounted or attached to the substrate (in addition to being directly attached). PO Resp. 11 (“The ordinary English reading of the claim language does not encompass the phosphor coating only being indirectly attached to the substrate, instead, the language indicates that the coating is directly applied to the substrate.” (emphasis changed)), 13 (“the phosphor coating . . . is not merely attached to the substrate indirectly”).” slip op. at 10
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“After considering Patent Owner’s arguments, which we address below, we agree with Petitioner that the combination of Wojnarowski and Martin discloses this limitation and that a person of ordinary skill in the art would have been motivated to combine the references’ teachings in the manner asserted by Petitioner. Briefly, we summarize our findings, and then we address the parties’ arguments in more detail. First, we agree with Petitioner, and Patent Owner does not dispute, that Wojnarowski’s AC input voltage would have been converted to DC voltage in light of the bridge rectifier and capacitor disclosed by Wojnarowski. Pet. 25; Ex. 1002 ¶¶ 119– 20 (citing, e.g., Ex. 1005, 7:59–62, Fig. 24); PO Resp. 35–36 (acknowledging Wojnarowski discloses converting an AC input to a DC voltage). Second, we further agree with Petitioner, and Patent Owner does not dispute, that excessive current due to too few LEDs would have harmed Wojnarowski’s LEDs, and too small a current due to too many LEDs would be insufficient to power Wojnarowski’s LEDs. Pet. 26; Ex. 1002 ¶ 134; PO Resp. 48 (discussing, but not disputing, these assertions).13 Third, we agree that a POSITA would have recognized in view of Martin’s teachings and the knowledge of a skilled artisan that when configuring Wojnarowski’s device, the total forward voltage drop of the series-connected LEDs should approximately match the DC voltage output 13 Petitioner explains the relationship between voltage and current for the LEDs as follows: “the total voltage drop of the circuit would dictate the current drawn by the LED circuitry, which would have been known to be inversely proportional to the voltage.” Pet. 26 (citing Ex. 1002 ¶ 134). of Wojnarowski’s circuit. Pet. 26–27 (citing Ex. 1002 ¶¶ 132–38; Ex. 1008, Abstract (LED voltage “must be matched to the input source voltage”), ¶ 60 (“For AC or any other regularly varying input voltage, there is an additional requirement to direct drive voltage matching”)). For example, Martin teaches that “[t]he number of LEDs in the monolithic array may be selected to achieve a particular voltage drop across each device.” Ex. 1006 ¶ 22. Martin further explains, “[t]he voltage across each of the individual LEDs in the array is the line voltage divided by the number of LEDs in series,” and “[t]he number of LEDs is chosen such that the maximum voltage across each individual LED during the peak in the alternating current cycle is low enough so as not to damage the LEDs.” Id. The forward voltage drop across Martin’s 38 LEDs is about 171 V, which matches Martin’s AC input voltage peak of about 169.71 V. See id. (“At 120 RMS volts, the peak voltage will be about 180V [correction: 169.71 V],” and if the LEDs “can tolerate a maximum forward voltage of 4.5V, at least 38 LEDs connected in series are required.” (38 LEDs x 4.5 V = 171 V)); PO Resp. 41–42 (“While Martin references ‘about 180V,’ both parties agree that the correct value of the peak voltage Vp is 169.71 V.” (citing Ex. 1002 ¶ 127)). Although Martin’s LED forward voltage drop (171 V) differs slightly from the peak input voltage (169.71 V), Patent Owner conceded at the hearing that the claimed “matches” does not require an exact equivalence. Tr. 38:9–11 (“Patent Owner agrees . . . that matching has a meaning that goes beyond exact equivalence.”).14” slip op. at 22
- Novelty / Anticipation (§102) › Prior-art status of a reference › Printed publication / public accessibilityPrinted publication establishedDecided for petitioner
“35 U.S.C. § 311(b). PO Resp. 22–25. This statute provides that “[a] petitioner in an inter partes review may request to cancel as unpatentable 1 or more claims of a patent only on a ground that could be raised under section 102 or 103 and only on the basis of prior art consisting of patents or printed publications.” § 311(b) (emphasis added). Patent Owner contends that Martin is not available as prior art under 35 U.S.C. § 311(b) because it is not a patent or printed publication and is only prior art under 35 U.S.C. § 102(e). PO Resp. 22. Patent Owner argues that documents are “printed publications” as of the date they become available to the public, and Martin became public on its publication date of October 21, 2004, after the February 25, 2004 priority date of the ’979 patent. Id. at 23. Patent Owner raises a similar argument for the Soules-II reference in Ground 6. Id. at 25– 26. Petitioner responds that the AIA framework permits the use of § 102(e) prior art in IPR proceedings, unlike formerly available covered business method review (CBM) proceedings, which restricted challenges to § 102(a) prior art. Reply 29. We agree. The statute governing the formerlyavailable CBM proceeding explicitly limits challenges based on “prior art that is described by section 102(a).” AIA § 18(a)(1)(C). In contrast, § 311(b) more broadly permits challenges “on the basis of prior art consisting of patents or printed publications.” The broader language in § 311(b) implies that unlike CBMs, IPRs are not limited to challenges solely under § 102(a) prior art. The parties cite to no Federal Circuit decisions that squarely address this issue. However, the Federal Circuit has applied § 102(e) patent application publication prior art in appeals from IPR proceedings. See, e.g., Purdue Pharma L.P. v. Iancu, 767 Fed. App’x 918, 920–21, 926 (Fed. Cir. 2019) (nonprecedential) (determining that a § 102(e) patent application publication was available as prior art in an IPR). The Board has also long permitted challenges based on patent application publications under § 102(e). See, e.g., Idle Free Sys., Inc. v. Bergstrom, Inc., IPR2012-00027, Paper 14 at 27 (PTAB Jan. 31, 2013) (instituting trial over § 102(e) ground based on a patent application publication). We therefore find Patent Owner’s § 311(b) argument unpersuasive.” slip op. at 34
Patent outcomesUS 10,652,979 mixedClaim construction§ 102 anticipation§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,652,979 - Home Depot USA, Inc. v. Lynk Labs, Inc.All claims unpatentablePTAB · Mar 29, 2023 · IPR2021-01540 · APJ Scott Raevsky · IPR · Final written decision
Claims 33, 34, 38, 39, and 43 are unpatentable as obvious over Teshima and SISE, or over Teshima, Butterworth, and SISE.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“[a] person of ordinary skill in the art (“POSITA”) . . . would have had a bachelor’s degree in electrical engineering, or similar technical field, with two years of relevant experience in the field of design and/or development of LEDs and circuits in the context of lighting control and networking systems. An increase in experience could compensate for less education. Pet. 10–11 (citing Ex. 1002 ¶ 34). Patent Owner states that it “adopts this definition of level of ordinary skill for purposes of this proceeding only.” PO Resp. 5. We are persuaded that Petitioner’s proposal is consistent with the problems and solutions in the ’842 patent and prior art of record. We adopt Petitioner’s definition of the level of skill.” slip op. at 6
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“We determine that no other terms require construction. See Realtime Data, LLC v. Iancu, 912 F.3d 1368 (Fed. Cir. 2019) (“The Board is required to construe ‘only those 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))).” slip op. at 8
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“We find Petitioner’s arguments more persuasive. As a threshold matter, we disagree with Patent Owner that “coated” requires a “thin layer.” We note that Patent Owner did not construe “coated” in its Patent Owner Response, relying only on a single citation to its expert declaration for the proposition that “coated” refers to a “thin layer.” PO Resp. 27 (citing Ex. 2007 ¶ 80). There, Dr. Bretschneider merely cites a dictionary definition without analysis or discussion in support of his testimony that “[c]oating an LED is adding a thin layer or covering to something.” Ex. 2007 ¶ 79. When questioned about this, he testified, “I didn’t equate that [statement in the declaration] to an opinion equivalent to claim construction.” Ex. 1038, 132:2–14. Patent Owner also does not discuss the intrinsic record in support of its implicit claim construction position. Based on our review of the intrinsic record, we can find no special definition or disavowal associated with the term “coated.” We also find Patent Owner’s dictionary definition unhelpful, as the meaning of “thin” layer is unclear. See Ex. 2007 ¶ 79. Moreover, Leung refers to “coating an LED with a phosphor layer” and that “it is often difficult to control the phosphor layer’s geometry and thickness,” which undercuts Patent Owner’s position that a coated layer must be thin. See Ex. 1037 ¶ 8.” slip op. at 26
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“We agree with Petitioner that SISE is analogous art to the ’842 patent. The field of endeavor of the ’842 patent is LED lighting systems. The ’842 patent explains that “LED based lighting may be used for general lighting, specialty lighting, signs, and decoration such as for Christmas tree lighting.” Ex. 1001, 1:66–2:2; see also id. at code (54) (“AC Light Emitting Diode and AC LED Drive Methods and Apparatus”). This is a broad field of endeavor, and we discern no relevant distinction between LED lighting systems that are used to illuminate an area or object and those used to signal information, such as traffic signals. Further, Patent Owner’s arguments here are inconsistent with its arguments in a related proceeding, IPR2021-01369. There, Patent Owner argued that the field of endeavor in a continuation patent of the ’842 patent was “LED lighting systems.” Home Depot USA, Inc. v. Lynk Labs, Inc., IPR2021-01369, Paper 45 at 17 (PTAB Feb. 14, 2023). Here, Patent Owner contends that the ’842 patent’s field of endeavor is “LED lighting systems and specifically circuits for driving LED lighting systems.” PO Resp. 42. As both patents share a common specification and Patent Owner does not explain why it proposes a different field of endeavor, we determine that the field of endeavor here is also “LED lighting systems.”” slip op. at 15
Patent outcomesUS 10,091,842 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,091,842 - Samsung Electronics Co., Ltd. v. Lynk Labs, Inc.All claims unpatentablePTAB · Mar 15, 2023 · IPR2021-01346 · APJ Scott Raevsky · IPR · Final written decision
Claims 3–16 are unpatentable as obvious under §103 over the seven combinations of prior art listed in the decision.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“These definitions are very similar, but we are persuaded that Patent Owner’s proposal is more consistent with the problems and solutions in the ’466 patent and prior art of record. Petitioner’s use of the term “and/or” is problematic because it makes experience with LED devices optional. In contrast, Patent Owner’s definition requires two or more years of experience with LED devices and related LED circuit design. We therefore adopt Patent Owner’s definition of the level of skill. Had we adopted Petitioner’s level of skill, however, the outcome here would not have changed.” slip op. at 6
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Neither party proposes any claim constructions. Pet. 6; PO Resp. 8–9; Reply 1. We determine that no terms require construction. See Realtime Data, LLC v. Iancu, 912 F.3d 1368 (Fed. Cir. 2019) (“The Board is required to construe ‘only those 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)).” slip op. at 7
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundUnpatentable
“We agree with Petitioner. Patent Owner indeed relies on an improper bodily incorporation argument. Petitioner does not propose bodily incorporating Siwinski and Srivastava together, but rather taking certain teachings from these references and applying them to Hack. Reply 11, 14. For example, Petitioner argues that a POSITA would have relied on Siwinski’s teachings “to configure Hack’s device to implement a circuit configured to detect touch via capacitive sensing.” Pet. 28 (citing Ex. 1002 ¶ 124). And Petitioner relies on Srivastava for the teaching that a POSITA would have configured Hack’s device with a lens doped with particles configured to receive and transmit light from a plurality of LEDs. Id. at 29– 30 (citing Ex. 1002 ¶¶ 126–32). Patent Owner’s argument that Srivastava’s shell is not combinable with Siwinski’s touch screen misdirects our attention to a combination that Petitioner did not propose, and is a bodily incorporation that fundamentally misapplies the law of obviousness. “The test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference . . . . Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art.” MCM Portfolio LLC v. Hewlett-Packard Co., 812 F.3d 1284, 1294 (Fed. Cir. 2015) (quoting In re Keller, 642 F.2d 413, 425 (CCPA 1981)). Regardless, Petitioner’s arguments are not conclusory. The Reply persuasively argues that “Srivastava’s express applicability to OLEDs and display backlights is consistent with Hack’s OLED backlight features.” Reply 11 (citing, e.g., Ex. 1052, 1:10–12, 5:29–38). We are further persuaded by Petitioner’s evidence supporting that “the use of a lens with LED backlight configurations was known,” which undercuts Mr. Credelle’s testimony that Srivastava’s lens would be incompatible with a touch screen backlight. Id. (citing, e.g., Ex. 1090 (depicting a lens over multiple OLED color elements), Fig. 13; Ex. 1098, code (57) (“display back lighting system” with an “entrance lens” and a “reflecting lens”); Ex. 1099, code (57) (“backlight assembly” with “a closely packed array of hemispherical or spherical lenses”)); see Ex. 2001 ¶¶ 96–97. And contrary to Mr. Credelle’s testimony that “[i]t would be illogical to form Srivastava’s shell over Siwinski’s touch screen because the shell would prevent touching the touch screen, which is the function of the touch screen,” Petitioner persuasively argues that “Srivastava explains that it was known that LEDs are used as a backlight in liquid crystal displays.” Reply 11. In other words, Petitioner’s reliance on Srivastava’s backlight teachings would not prevent a user from touching a screen (in front of the backlight) in the modified device. Accordingly, we agree with Petitioner that one of ordinary skill in the art would have combined Hack, Siwinski, and Srivastava to achieve this limitation.” slip op. at 16
- Strike new argumentNew argument disregardedDecided for petitioner
“We start our analysis with the Sur-reply because it exposes several weaknesses in Patent Owner’s arguments. First, contrary to what the Sur-reply contends, the Patent Owner response did not argue that “Srivastava’s LED shell is incompatible with Hack’s touch screen because the hard shell would interfere with the functionality of the touchscreen.” Id. This is a new argument first made in the Sur-reply, and we do not consider it. See 37 C.F.R. § 42.23(b). What Patent Owner actually argued in its Response was that “[a] POSITA would not combine Srivastava’s LED shell for a single LED with Hack’s flexible display.” PO Resp. 24. There is no mention of a “hard shell” interfering with the functionality of the touch screen in the Patent Owner Response. See id. At most, Patent Owner contends that the shell would “prevent touching the screen,” and that the “curvature of the shell” would be incompatible, not that any hardness of the shell would present a problem. Id. at 25–26 (quoting Ex. 2001 ¶ 97). Regardless, even if we consider this argument, it is inapposite because as the Reply correctly notes, “Srivastava explains that it was known that LEDs are used as a backlight in liquid crystal displays,” and we accordingly find that a backlight with a hard shell would not interfere with a user touching a display. See Reply 11 (citing Pet. 30–33; Ex. 1052, 1:10–12).” slip op. at 28
Patent outcomesUS 10,499,466 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,499,466 - Samsung Electronics Co., Ltd. v. Lynk Labs, Inc.All claims unpatentablePTAB · Mar 15, 2023 · IPR2021-01345 · APJ Scott Raevsky · IPR · Final written decision
Claims 4, 9–11, 13, 17, 18, and 20 are unpatentable as obvious over Hack and Garcia, Hack, Garcia, and Cordelli, or Hack and Porter.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“Patent Owner contends that a person of ordinary skill in the art (“POSITA”) would mean someone who, at the time of the invention in February 2004, had at least a bachelor’s degree in electrical engineering, computer engineering, computer science, physics, or the equivalent, and two or more years of experience with LED devices and related LED circuit design. PO Resp. 7 (citing Ex. 2001 ¶¶ 41–48). Petitioner contends that there is little difference between these definitions and that Patent Owner does not tie any of its arguments to the minor differences. Reply 1–2. We agree. However, we adopt Patent Owner’s definition of the level of skill because we are persuaded that it is consistent with the problems and solutions in the ’252 patent and prior art of record, except that we delete the phrase “or more” to avoid including ambiguity in the definition of the level of skill. The outcome of this decision would not have changed had we adopted Petitioner’s definition.” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededNot reached
“Because the intrinsic record7 does not assist us with interpreting the term “folded,” we turn to the extrinsic evidence, including Patent Owner’s proffered dictionary definitions and expert testimony. As mentioned above, Patent Owner supplied two dictionary definitions for “fold.” See Exs. 2006, 2007. But these definitions are from non-technical sources and are non-contemporaneous with the ’252 patent’s priority date, and are thus of limited relevance to our analysis. Reply 14 n.7. As for expert testimony, Patent Owner’s expert submits that “[a] POSITA would understand that folding a substrate requires bending the substrate so that one part of the substrate is in full contact with another part of the substrate.” Ex. 2001 ¶ 81. However, Patent Owner’s expert provides no evidence or explanation for this conclusory assertion, so we give it little weight. See id.; PO Resp. 18–19; 37 C.F.R. § 42.65(a). Further, as we will discuss in detail below, the prior art upon which 7 The parties do not address the prosecution history. Petitioner relies explicitly discloses a substrate that is flexible enough to be folded. See, e.g., Pet. 40; Ex. 1005 ¶ 76 (“[T]he display 106 could be thin and flexible enough to . . . fold into a housing 102[.]”). Thus, apart from explaining the errors in Patent Owner’s proposed construction, we determine that it is unnecessary for us to further analyze the proper scope of this term. See Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those 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)).” slip op. at 11
- Expert testimonyPatent owner expert discountedPetitioner expert creditedDecided for petitioner
“Because the intrinsic record7 does not assist us with interpreting the term “folded,” we turn to the extrinsic evidence, including Patent Owner’s proffered dictionary definitions and expert testimony. As mentioned above, Patent Owner supplied two dictionary definitions for “fold.” See Exs. 2006, 2007. But these definitions are from non-technical sources and are non-contemporaneous with the ’252 patent’s priority date, and are thus of limited relevance to our analysis. Reply 14 n.7. As for expert testimony, Patent Owner’s expert submits that “[a] POSITA would understand that folding a substrate requires bending the substrate so that one part of the substrate is in full contact with another part of the substrate.” Ex. 2001 ¶ 81. However, Patent Owner’s expert provides no evidence or explanation for this conclusory assertion, so we give it little weight. See id.; PO Resp. 18–19; 37 C.F.R. § 42.65(a).” slip op. at 11
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)UnpatentableUnpatentable
“We agree with Petitioner that Garbuzov discloses stacked LEDs, with a coating on one of those LEDs, notwithstanding Patent Owner’s arguments to the contrary, which we discuss in detail below. To briefly summarize, first, we agree with Petitioner (and Patent Owner does not dispute) that Figure 39 (above) of the ’252 patent depicts an OLED. Second, we agree that each of the sets of layers Petitioner identifies in Garbuzov as an OLED has a similar structure as the OLED in Figure 39 of the ’252 patent, and is therefore an OLED. See, e.g., Ex. 1089, 48:3–6. Third, we agree with Petitioner that the phosphor layer 114 is applied to one of Garbuzov’s OLEDs within the stacked set of OLEDs, as shown in Garbuzov Figure 2, and therefore, that Garbuzov discloses coating an LED with a phosphor. Finally, we agree with Petitioner that phosphor layer 114 produces a change in color because Garbuzov describes phosphor layer 114 as “red downconversion phosphor layer 114.” See Ex. 1016, 3:32–33.” slip op. at 25
Patent outcomesUS 10,492,252 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,492,252 - Samsung Electronics Co. Ltd. v. Lynk Labs, Inc.All claims unpatentablePTAB · Mar 13, 2023 · IPR2021-01347 · APJ Jon B Tornquist · IPR · Final written decision
Claims 1–17 and 21–25 are unpatentable: claims 6 and 24 are anticipated by Birrell; the remaining challenged claims are obvious over the stated combinations.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“Patent Owner contends there are “several problems” with Petitioner’s proposed definition. PO Resp. 11. In particular, Patent Owner contends the “and/or” qualifier and addition of “or a related field” could be read to allow an individual with no experience with LED devices to be a person of ordinary skill in the art. Id. Upon review of the parties’ arguments, the prior art of record, and the ’298 patent, we agree with Patent Owner that one of ordinary skill in the art would have had experience working with LEDs and/or LED circuit design. Thus, we adopt Patent Owner’s definition of one of ordinary skill in the art. We note, however, that neither party asserts that the outcome of this case rests on resolving the small differences between the parties’ definitions of the ordinarily skilled artisan.” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for patent owner
“C. Claim Construction In this proceeding, the claims of the ’298 patent are construed “using the same claim construction standard that would be used to construe the claim in a civil action under 35 U.S.C. [§] 282(b).” 37 C.F.R. § 42.100(b). Under that standard, the words of a claim are generally given their “ordinary and customary meaning,” which is the meaning the term would have had to a person of ordinary skill at the time of the invention in the context of the 1303, 1312–13 (Fed. Cir. 2005) (en banc). Neither party contends any terms of the ’298 patent require construction. Pet. 5–6; PO Resp. 12. Upon review of the parties’ arguments and supporting evidence, we agree that no terms require express construction. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.”)).” slip op. at 8
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningDecided for petitioner
“By its express language, the claim term “wirelessly” is best understood as “without the use of a wire.” We are directed to no disclosure in the written description or prosecution history that would contradict this conclusion or otherwise shed light on the meaning of this claim term. There is no dispute that capacitive coupling does not use a wire or any other form of direct contact to transmit power. Thus, the plain meaning of “wirelessly” encompasses capacitive coupling. This conclusion is supported 6,336,031 states that “[c]onnectionless (i.e., wireless) transmission of analog and digital signals has previously been accomplished using . . . [c]apacitive coupling.” Ex. 1131, 1:10–18. Likewise, U.S. Patent No. 6,988,026 describes a “power receiving system which receive[s] power wirelessly (inductively, through radio frequency energy transfer and/or capacitively).” Ex. 1133, 113:64–114:2. Mr. Credelle’s counter-testimony is not persuasive because he does not explain in any detail why one of ordinary skill in the art would not understand a capacitive coupling that transfers power to be a wireless system. See Ex. 2001 ¶ 80.” slip op. at 50
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“KSR instructs that “[t]he combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results.” KSR, 550 U.S. at 416. Here, Petitioner proposes to substitute one known method of transmitting power for another (an inductor in place of two capacitors), according to known methods (Logan), and Patent Owner does not dispute that the combination would yield a predictable result of wirelessly providing power from one device to another. This suggests that the proposed combination would have been obvious. Id. point to a specific problem discussed in Birrell for which Logan’s method of using inductive coupling would be a solution. See In re Heck, 699 F.2d 1331, 1333 (Fed. Cir. 1983) (“The use of patents as references is not limited to what the patentees describe as their own inventions or to the problems with which they are concerned. They are part of the literature of the art, relevant for all they contain.”) (internal quotations omitted). What the Petition must demonstrate is that there was some reason why one of ordinary skill in the art would have sought to combine the elements in the manner proposed. KSR, 550 U.S. at 418. The Petition provides multiple, persuasive reasons (discussed above) as to why one of ordinary skill in the art would have sought to use inductors, as disclosed in Logan, to wirelessly transmit power to a lighting device, such as that disclosed in Birrell.13 (d) Conclusion For the reasons set forth above, we find that Petitioner presents multiple, persuasive reasons as to why one of ordinary skill in the art would have sought to implement the wireless power transmission system of Logan in the lighting device of Birrell.” slip op. at 19
Patent outcomesUS 10,966,298 unpatentableClaim construction§ 102 anticipation§ 103 obviousnesscites KSR · GrahamPatents in suitUS 10,966,298 - Samsung Electronics Co. Ltd. v. Lynk Labs, Inc.All claims unpatentablePTAB · Mar 13, 2023 · IPR2021-01300 · APJ Jon B Tornquist · IPR · Final written decision
Claims 1–22 are unpatentable as obvious under §103 over the asserted combinations of Oba and the additional references listed for each ground.
RulingsFinal written decision- Skill levelSkill level patent owner adoptedDecided for patent owner
“Patent Owner provides a very similar definition of the ordinarily skilled artisan, but removes the “and/or” qualifier for experience with LED devices, as well as the allowance for individuals to have experience in an unspecified “related field.” PO Resp. 5. Patent Owner contends these modifications are appropriate because Petitioner’s proposed definition would allow an individual with no experience with LEDs to be a person of ordinary skill in the art. Id. art of record, we adopt Patent Owner’s definition of the ordinarily skilled artisan as it is consistent with the disclosures of the ’697 patent and with the prior art of record. We note, however, that neither party asserts that any arguments in this proceeding rise or fall based on the definition that is adopted.” slip op. at 7
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for patent owner
“Neither party contends any terms of the ’697 patent require construction. And, upon review of the parties’ arguments and supporting evidence, we determine that no terms require construction for purposes of this Decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.”)).” slip op. at 8
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundUnpatentable
“Petitioner provides uncontroverted testimony from Dr. Baker, which we credit, that: (1) Oba’s laptop computer necessarily has a battery ground (Ex. 1002 ¶ 102); (2) it was known in the art, for example as disclosed in Hara, that a capacitor could be coupled between a battery ground and the circuit elements powered by the device in order to serve as a filter for noise (id. ¶¶ 103, 108; Ex. 1090 ¶ 3 (asserting that AC power is a known source of noise)); and (3) capacitively coupling Oba’s battery ground to the conductor connecting the battery poles and the circuit components of the laptop computer would “smooth delivered power,” thereby “facilitating a steady supply of power” (Ex. 1002 ¶¶ 104–106). As argued by Patent Owner, Hara uses a capacitive coupling to battery ground in order to mitigate standing waves caused by the extended length of the conductors connecting the laptop battery to circuit components. PO Resp. 15. The capacitive-coupling to battery ground, however, need not be used in Oba to solve the same problem identified in Hara, and Dr. Baker persuasively explains why the system of Oba would benefit from a ¶¶ 103–104; Ex. 1090 ¶ 3–10 (asserting that AC power is a known source of noise). As such, Petitioner persuasively explains why one of ordinary skill in the art would have sought to combine Oba and Hara to arrive at a battery ground that is capacitively coupled to the circuit components of the laptop computer. c)” slip op. at 18
Patent outcomesUS 11,019,697 unpatentableClaim construction§ 103 obviousnesscites KSR · GrahamPatents in suitUS 11,019,697 - Home Depot USA, Inc. v. Lynk Labs, Inc.All claims unpatentablePTAB · Feb 14, 2023 · IPR2021-01369 · APJ Jon B Tornquist · IPR · Final written decision
Claims 1, 11, and 13 are unpatentable as obvious over the respective combinations of Deese, Kuo, and Obeck; Deese and Kuo; and Okuno and Teshima.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“B. Level of Ordinary Skill in the Art In determining the level of ordinary skill in the art, we consider the type of problems encountered in the art, the prior art solutions to those problems, the rapidity with which innovations are made, the sophistication of the technology, and the educational level of active workers in the field. Custom Accessories, Inc. v. Jeffrey-Allan Indus., Inc., 807 F.2d 955, 962 (Fed. Cir. 1986).” slip op. at 6
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner
“C. Claim Construction In this proceeding, the claims of the ’251 patent are construed “using the same claim construction standard that would be used to construe the claim in a civil action under 35 U.S.C. [§] 282(b).” 37 C.F.R. § 42.100(b) (2001). Under that standard, the words of a claim are generally given their “ordinary and customary meaning,” which is the meaning the term would have had to a person of ordinary skill at the time of the invention in the context of the entire patent including the specification. Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc).” slip op. at 7
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“a) Analogous Art To resolve whether art is analogous we must determine “(1) whether the art is from the same field of endeavor, regardless of the problem addressed and, (2) if the reference is not within the field of the inventor’s endeavor, whether the reference still is reasonably pertinent to the particular problem with which the inventor is involved.” In re Bigio, 381 F.3d 1320, 1325 (Fed. Cir. 2004).” slip op. at 16
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“c) Reason to Combine As noted above, Petitioner contends one of ordinary skill in the art would have sought to add data signal preemption capabilities in Deese and Kuo because (1) Deese, Kuo, and Obeck are analogous art to the ’251 patent (i.e., are all in the field of lighting systems), (2) “[t]he need for signal preemption was well-known in the art,” and (3) Obeck expressly teaches that its use of a data receiver solves the need for signal preemption in traffic lights. Pet. 15–16. Petitioner contends one of ordinary skill in the art would have had a reasonable expectation of success in implementing Obeck’s data receiver and signal preemption method in Deese because Deese’s signal controller 70 is a “conventional” controller for selectively energizing the red, yellow, and green traffic lights and this is “precisely the same type of ‘regular signal control 71’ that Obeck teaches should be supplemented with 5:45–63; 1006, 6:36–48; Ex. 1002 ¶ 51).” slip op. at 23
Patent outcomesUS 10,492,251 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,492,251 - Home Depot USA, Inc. v. Lynk Labs, Inc.All claims unpatentablePTAB · Feb 14, 2023 · IPR2021-01367 · APJ Jon B Tornquist · IPR · Final written decision
Claims 1, 3, 4, 5, 7, and 8 are unpatentable as obvious over the Deese-based grounds; the Board did not reach the Lys- and Worley-based grounds.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“February 25, 2004, would have had “a Bachelor’s degree in electrical engineering, or similar technical field, with two years of relevant experience in the field of design and/or development of light-emitting diodes (LEDs) and circuits in the context of lighting control systems.” Pet. 14 (citing Ex. 1002 ¶ 24). For purposes of this proceeding, Patent Owner does not dispute Petitioner’s definition of a person of ordinary skill in the art. PO Resp. 11. Upon review of the prior art of record and Petitioner’s arguments, we adopt Petitioner’s undisputed definition of a person of ordinary skill in the art for purposes of this Final Written Decision, as it is consistent with the disclosures of the ’551 patent and the prior art of record.” slip op. at 6
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Term construed petitioner constructionDecided for petitioner
“In the Institution Decision, we construed “driver” to mean “a program, circuitry, or device used to power other programs, circuits, or devices.” Inst. Dec. 14. We also asked the parties to address whether the term “mounted,” as used in independent claims 1 and 5, permits indirect contact between the various components and the reflective substrate. Id. at 32 n.11. Patent Owner contends the Board’s adopted construction of “driver” is too broad, but because the arguments presented in Patent Owner’s Response to do not turn on a narrower construction of “driver,” it does not propose an alternate construction of the claim term. PO Resp. 12–13. Patent Owner does not address the scope of the term “mounted” in its Response or ask that any other claim terms be expressly construed. Upon review of the parties’ arguments and supporting evidence, we adopt our previous construction of “driver” and determine that we need not construe any additional claim terms for purposes of this Final Written Decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those terms need be construed that are in controversy, and only to the extent necessary to resolve the controversy.”)). We note, however, that we do provide” slip op. at 7
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“Kuo discloses a “high efficiency light” that uses LEDs to emit light, as well as different lenses to amplify the intensity of the light emitted from the LEDs. See Ex. 1013, 1:6–9. Although Kuo focuses primarily on using its light as a traffic signal, Kuo is not limited to this embodiment and broadly claims “[a] high efficiency light.” Id. at 3:14–4:23 (Compare claim 1 directed to “[a] high efficiency light,” with claim 2 directed to use of the light of claim 1 “as a signal light”). Thus, we find that Kuo is in the same field of endeavor as the ’551 patent, i.e., LED lighting systems. that Kuo meets the “reasonably pertinent” prong of the analogous art test. KSR instructs that “familiar items may have obvious uses beyond their primary purposes, and a person of ordinary skill in the art often will be able to fit the teachings of multiple patents together like pieces of a puzzle.” KSR, 550 U.S. 398, 402 (2007). Given this instruction, the Federal Circuit has explained that when considering whether prior art is reasonably pertinent we must look beyond the primary problem the inventor was seeking to solve. See Wyers v. Master Lock Co., 616 F.3d 1231, 1238 (Fed. Cir. 2010) (explaining that in analyzing whether the prior art is reasonably pertinent we must construe the scope of analogous art “broadly”); see also Donner Tech., LLC. V. Pro Stage Gear, LLC, 979 F.3d 1353, 1360 (Fed. Cir. 2020) (explaining that the “reasonably pertinent” analysis must look to all of the problems to which the claimed invention relates, and must not be analyzed so narrowly as to effectively collapse the “field-of-endeavor and reasonablepertinence inquiries”). Here, although the ’551 patent is primarily focused on ways to efficiently drive LEDs using AC power, the ’551 patent is also concerned with methods of assembling an LED lighting system, including the use of: an insulating substrate, a heat sink, a reflective material on which to mount the LEDs, a lens for directing light, and a light changing or enhancing substance(s). Ex. 1001, 5:6–31, code (54) (noting that the ’551 patent is directed to both AC LED drive methods and an apparatus). Kuo expressly discloses the design of a housing that uses a lens and a light reflecting surface to maximize the light obtained from LEDs. These disclosures are reasonably pertinent to at least one problem the ’551 patent was intended to solve, e.g., what techniques and materials should be used to construct an analogous art to the ’551 patent under both prongs of the analogous art test.” slip op. at 15
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“5. Conclusion For the reasons set forth above, and upon review of the record as a whole, we determine that Petitioner persuasively identifies where Deese and Kuo teach or suggest every limitation of independent claims 1 and 5 of the ’551 patent. Petitioner also provides a reasoned explanation as to why one of ordinary skill in the art would have combined the teachings of Deese and Kuo to arrive at the subject matter of claims 1 and 5 with a reasonable expectation of success. Accordingly, Petitioner demonstrates by a” slip op. at 18
Patent outcomesUS 10,154,551 unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,154,551
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.