• Apple Inc. v. LBT IP I LLCNo claims unpatentable
  PTAB · Dec 15, 2023 · IPR2020-01189 · APJ John A Hudalla · IPR · Remand

  Claims 8, 10, 13, and 15 were not shown unpatentable because Sakamoto discloses only two battery power thresholds, which do not meet the construed multitude limitation.

  RulingsRemand decision

  • Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITAPlain and ordinary meaningTerm construed patent owner constructionDecided for patent owner

    “threshold values” includes GPS signal level thresholds, we start with the words of claim 8. Claim 8 recites a “battery power level monitor” that (1) “measures a power level of the charging unit” and (2) “adjusts a power level applied to location tracking circuitry responsive to one or more signal levels.” Claim 8 further recites that “the power level compris[es] a multitude of threshold values determined by a user or system administrator.” The remainder of claim 8 states the purpose of the “multitude of threshold values,” which is “to intermittently activate or deactivate the location tracking circuitry to conserve power of the charging unit in response to the estimated charge level of the charging unit.” The natural reading of these recitations is that the “power level” associated with the “multitude of threshold values” is the battery power level that is (1) measured by the battery power level monitor and (2) adjusted by the battery power level monitor and applied to location tracking circuitry. We also note that the claim language already incorporates a limitation directed to “signal levels” insofar as the battery power level monitor “adjusts a power level applied to location tracking circuitry responsive to one or more signal levels” (emphasis added). As such, the limitation “one or more signal levels” is recited separately from the limitation “the power level comprising a multitude of threshold values.” Given “[t]he general presumption that different terms have different meanings,” Chicago Bd. Options Exch., Inc. v. Int’l Sec. Exch., LLC, 677 F.3d 1361, 1369 (Fed. Cir. 2012), we ascribe different meanings to the recited “signal levels” and “power level.”” slip op. at 15

  • Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Not shown unpatentableNot shown unpatentable

    “the battery power thresholds between (1) high and normal sensitivity positioning modes and (2) normal sensitivity positioning mode and turning off power to the GPS receiver) and Sakamoto’s two GPS signal level thresholds (i.e., K1 and K2) for teaching “the power level comprising a multitude of threshold values.” Pet. 50–51; Pet. Reply 16–18. As discussed above, however, “the power level comprising a multitude of threshold values” refers to battery power level thresholds. See supra § II.C.2. We also determine above that signal level threshold values are not within the scope of “the power level comprising a multitude of threshold values.” See id. Accordingly, we are not persuaded that Sakamoto’s GPS signal level thresholds K1 and K2 teach the recited power level threshold values. Although Petitioner is correct that “Sakamoto uses the same modes with both sets of thresholds” and that both sets of thresholds might ultimately relate to conserving battery power (see Pet. Reply 17 (citing Ex. 1003 ¶ 58; Ex. 1004 ¶¶ 27–29)), we are not persuaded that these different types of thresholds are interchangeable within the scope of “the power level comprising a multitude of threshold values.” This is particularly true given that Petitioner already relies on Sakamoto’s GPS signal level thresholds K1 and K2 for teaching another aspect of claim 8, i.e., “responsive to one or more signal levels.” See Pet. 49–50. For these reasons, Petitioner has only established that Sakamoto teaches two battery power level thresholds within the scope of “the power level comprising a multitude of threshold values.” Because two threshold values are not a “multitude” (see supra § II.C.1), we find that Petitioner has not established that Sakamoto teaches “the power level comprising a multitude of threshold values,” as recited in claim 8. Thus, we determine Petitioner has not shown by a preponderance of the evidence that the subject matter of claim 8 would have been obvious over Sakamoto. 3. Claims 10, 13, and 15 Claims 10, 13, and 15 each depend from claim 8. Ex. 1001, 17:4–10, 17:23–25, 17:29–33. Petitioner’s analysis for these claims does not cure the deficiencies discussed above with respect to claim 8. See Pet. 54–55. Thus, we determine Petitioner has not shown by a preponderance of the evidence that the subject matter of claims 10, 13, and 15 would have been obvious over Sakamoto.” slip op. at 31

  • BurdenNot shown unpatentable

    “III. CONCLUSION Petitioner has not shown, by a preponderance of the evidence, that (1) the subject matter of claims 8, 10, 13, and 15 would have been obvious over Sakamoto; (2) the subject matter of claims 8, 10, 13, and 15 would have been obvious over the combination of Sakamoto and AAPA; or (3) the subject matter of claims 8, 10, 13, and 15 would have been obvious over the combination of Sakamoto and Hayasaka.” slip op. at 33

  Patent outcomesUS 8,497,774 not shown unpatentable
  Claim construction§ 103 obviousnesscites Phillips · KSR · Graham
  Patents in suitUS 8,497,774

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.