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  • PTAB · Dec 2, 2025 · IPR2024-01052 · APJ Brian D Range · IPR · Final written decision

    Claims 1, 2, 7–12, and 17–20 are unpatentable as obvious; claims 3–6 and 13–16 were not shown unpatentable because the asserted Watanabe combinations were unsupported.

    RulingsFinal written decision
    • Skill levelSkill level petitioner adoptedDecided for petitioner

      “cameras.” Pet. 6 (citing Ex. 1002 ¶¶ 36–38). Petitioner further contends “[a]n advanced graduate degree in the disciplines cited above may make up for the work experience indicated above.” Id. Patent Owner does not dispute and applies Petitioner’s proposed level of skill. PO Resp. 6. We find that Petitioner’s proposal is reasonable and consistent with the ’832 patent specification and the prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art). Thus, we apply Petitioner’s proposal in our analysis.” slip op. at 13

    • Prior constructionPrior construction adoptedDecided for petitioner

      “In our Institution Decision, we construed “determin[ing] a viewing window for the visual content as a function of progress through the progress length” as “requiring determining a viewing window for different times of the video.” Inst. Dec. 21. Neither party disputes this construction. PO Resp. 7; Pet. Reply 1–7. We maintain this same construction.” slip op. at 13

    • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner

      “Thomason are in the same field of endeavor. Thomason describes a camera and method for correctly orientating pictures from the camera. See, e.g., Ex. 1004 ¶¶ 1, 2 29–40, Figs. 3a–3b. In particular, Thomason is interested in rotating and cropping images to reduce the effect of poor orientation. Pet. 9 (citing Ex. 1004 ¶¶ 2, 34, 36). Pacurariu likewise describes aligning and resizing/cropping of a captured image to correct poor orientation. See, e.g., Ex. 1005 ¶¶ 1, 3, 45–56, Figs. 5A–5C. The preponderance of the evidence also supports that a person having ordinary skill in the art would have had reason to combine the Pacurariu’s teachings with Thomason to predictably improve Thomason. Thomason teaches correct rotation of video data and makes use of rotation sensor to correct rotated images. Pet. 19–21 (citing, e.g., Ex. 1004 ¶¶ 4, 27, 29, 35; Ex. 1002 ¶¶ 76–77). Pacurariu similarly uses sensors and measures tilt angle of the camera. Id at 21–22 (citing, e.g., Ex. 1005 ¶¶ 51–52, Fig. 6; Ex. 1002 ¶ 78). Pacurariu further teaches that its tilt data angle can be stored for each “video frame.” Id. at 22 (citing Ex. 1005 ¶ 52). Petitioner, with support from credible testimony of Dr. Katsaggelos, explains how the teachings of Thomason and Pacurariu could be successfully combined. Id. at 23 (citing, for example, Ex. 1002 ¶ 81). A person of ordinary skill in the art could have known that Thomason’s system could be improved by saving rotation data for each video frame and correcting images on a frame-by-frame basis. Id. at 23–24. The testimony of Dr. Katsaggelos is credible in this regard. Ex. 1002 ¶¶ 80–81. Petitioner and Dr. Katsaggelos explain the references’ teachings and, based on these teachings, assert that a person having skill in the art would have had reason to combine with reasonable expectation of success based on those teachings. Reason to combine may properly come from the references themselves. KSR Int’l Co., 550 U.S. at 418 (explaining reason to combine may come from “interrelated teachings of multiple patents”). Based on the evidence presented, Petitioner establishes by a preponderance of the evidence that a person having ordinary skill in the art would have had reason to combine the teachings of Thomason and Pacurariu with a reasonable expectation of success. Ex. 1002 ¶¶ 76–81, 89–92; Ex. 1004 ¶¶ 4, 8–9, 27, 29, 35; Ex. 1005 ¶¶ 26, 41, 46, 51–52, 55–57, Figs. 6, 7.” slip op. at 27

    • Obviousness (§103) › Objective indicia / secondary considerations › NexusObjective indicia no nexusDecided for patent owner

      “evaluating nexus between the claimed invention and objective evidence of nonobviousness, also referred to as secondary considerations. Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 33 at 33 (PTAB Jan. 24, 2020) (precedential). We first consider whether Patent Owner has demonstrated “that its products are coextensive (or nearly coextensive) with the challenged claims,” resulting in a rebuttable presumption of nexus. Id. at 33. If not, that “does not end the inquiry into secondary considerations”; “the patent owner is still afforded an opportunity to prove nexus by showing that the evidence of secondary considerations is the ‘direct result of the unique characteristics of the claimed invention.’” Id. (quoting Fox Factory, 944 F.3d at 1373–75).” slip op. at 62

    Patent outcomesUS 11,336,832 mixed
    Claim construction§ 103 obviousnesscites KSR · Graham
    Patents in suitUS 11,336,832
  • PTAB · Oct 23, 2025 · IPR2024-00983 · APJ Norman H Beamer · IPR · Final written decision

    Claims 1–6, 10, 17, 19, and 20 are unpatentable under § 103 over Alexander and Cosper; the alternative Gregorio-based grounds did not establish unpatentability.

    RulingsFinal written decision
    • Claim Construction › Functional claiming / §112(f) means-plus-function › Whether §112(f) applies (Williamson, nonce words)§112(f) appliesDecided for patent owner

      “112(f). Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1348 (Fed. Cir. 2015). But if the term does not use the word “means,” then it is presumed not to be subject to Section 112(f). Id. “That presumption can be overcome, but only if the challenger demonstrates that the claim term fails to recite sufficiently definite structure or else recites function without reciting sufficient structure for performing that function.” Samsung Elecs. Am., Inc. v. Prisua Eng’g Corp., 948 F.3d 1342 (Fed. Cir. 2020). “The correct inquiry, when ‘means’ is absent from a limitation, is whether the limitation, read in light of the remaining claim language, specification, prosecution history, and relevant extrinsic evidence, has sufficiently definite structure to a person of ordinary skill in the art.” Apple Inc. v. Motorola, Inc., 757 F.3d 1286, 1298 (Fed. Cir. 2014).” slip op. at 12

    • Prior constructionPrior construction adoptedDecided for patent owner

      “both parties have asserted in the Apple Litigation that the “control component” requirement is a means-plus-function limitation subject to 35 U.S.C. §112(f), despite the fact that the control component limitation does not recite “means for.” Pet. 3 (citing Ex. 1012, 3–8; Ex. 1013, 13); PO Resp. 6–7. Indeed, the court in the Apple Litigation has concluded that the control component requirement is subject to 35 U.S.C. § 112(f), and has construed that requirement accordingly: Function: receiving control signals input to the oscillating resonant module; receiving outputs from the one or more sensors; controlling oscillation of the mass to produce a vibration response according to the received control signals by generating, using one or more of the received sensor outputs, control outputs to an actuator that drives the mass to oscillate. Structure: a microcontroller, a processor, a microprocessor, or a CPU that performs the algorithm shown in Figure 45 or the algorithm described in the corresponding text. See, e.g., 31:19–32:13, and equivalents thereof. Ex. 2001, 10; Ex. 2002, 40. Because of the Apple Litigation record, Petitioner presents its challenges in the alternative, first applying a plain meaning approach to the control component requirement, and also analyzing the requirement under the construction adopted in the Apple Litigation. Pet. 3–5. We adopt the court’s construction in the Apple Litigation. 35 U.S.C.” slip op. at 11

    • Skill levelSkill level petitioner adoptedDecided for petitioner

      “Petitioner’s expert declarant contends that person of ordinary skill in the art (POSITA) “would have had a degree in mechanical engineering, electrical engineering, physics, or a related technical field, and at least 2–3 years of experience related to the design or development of vibration-generating systems; additional years of experience could substitute for the advanced-level degree.” Ex. 1003 ¶ 27. Patent Owner offers “a similar level of ordinary skill in the art.” PO Resp. 2. Based on a review of the record, we adopt Petitioner’s proposed level of ordinary skill in the art because it is consistent with the evidence of record, including the asserted prior art and ’882 patent specification.” slip op. at 9

    • Obviousness (§103) › Analogous artAnalogous artDecided for petitioner

      “(1) Analogous Art Our reviewing court has stated that “[t]wo separate tests define the scope of analogous prior art: (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) (citations and internal quotes omitted). While these two criteria are helpful in many instances, we must not lose sight of the key question at hand: what is “prior art” as that term is used in 35 U.S.C. § 103(a)? References that are “too remote to be treated as ‘prior art’” are excluded from the obviousness analysis. In re Sovish, 769 F.2d 738, 741, 226 (Fed. Cir. 1985). The non-analogous art test provides helpful insight on the underlying question of what is “prior art” within the meaning of the statute; we should not, however, be blind to the reality of the circumstances of the case before us. In re Wood, 599 F.2d 1032, 1036 (CCPA (1979). Nor should we adhere to rigid and mandatory formulas that overly limit the inquiry. KSR Int’l Co., 550 U.S. at 419.” slip op. at 22

    Patent outcomesUS 11,152,882 unpatentable
    Claim construction§ 103 obviousnesscites KSR · Graham
    Patents in suitUS 11,152,882
  • PTAB · Oct 9, 2025 · IPR2024-00698 · APJ Brian D Range · IPR · Final written decision

    Claims 1–5 are unpatentable as obvious under § 103 based on the asserted combinations of Izumi, Cosper, Rossi, Ibuki, and Aldrich.

    RulingsFinal written decision
    • Skill levelSkill level petitioner adoptedDecided for petitioner

      “Petitioner contends that a person of ordinary skill in the art (POSITA) would have had a degree in mechanical engineering, electrical engineering, physics, or a related technical field, and at least 2–3 years of experience related to the design or development of systems incorporating linear actuators; additional years of experience could substitute for the degree. Pet. 4 (citing Ex. 1003 ¶ 30–31). Patent Owner contends a POSITA would have had (1) a bachelor’s degree in electrical engineering, mechanical engineering, or a comparable field of study, and (2) at least two years of professional experience with electro-mechanical control systems, or other similarly relevant industry experience. PO Resp. 2–3. Additional relevant industry experience may compensate for lack of formal education or vice versa. Id. Patent Owner further contends this is similar to Petitioner’s POSITA contention. Id. at 3. For purposes of this Decision, we adopt Petitioner’s proposal as reasonable and consistent with the ’767 patent specification and the prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art). Our reasoning herein would be the same under Patent Owner’s similar proposal.” slip op. at 8

    • Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble limitingDecided for petitioner

      “Claim 1, Preamble. Both parties agree that the preamble of claim 1 is limiting. PO Resp. 6. We agree that claim 1’s preamble is limiting. We also note that the parties agreed that this preamble is limiting in the District Court case. Dist. Ct. Const. 10.” slip op. at 9

    • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner

      “Because neither party asserts that construction of “driving component” or “control component” is necessary to resolve the issues before us, we decline to expressly construe these claim terms. See, e.g., 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)). For clarity, because Petitioner argues that plain and ordinary meaning is appropriate and because Patent Owner does not dispute that construction, we adopt the plain and ordinary meaning of these claim terms when comparing the challenged claims to the prior art. Other claim terms. It is unnecessary for us to expressly construe other claim terms for purposes of this Decision. See, e.g., Realtime Data, LLC, 912 F.3d at 1375.” slip op. at 10

    • Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundDecided for petitioner

      “Petitioner argues that a person having ordinary skill in the art would have combined Izumi’s module to include multiple sensors in accordance with Cosper’s teachings. Pet. 15. Petitioner argues that the sensors would monitor the moving element and generate a control signal in accordance with Izumi. Id. at 15–16. Petitioner further argues that Izumi’s controller would have been implemented using a microprocessor and memory as Cosper suggests. Id. at 16. Petitioner argues three reasons why a person having ordinary skill in the art would have combined Izumi with Cosper’s teachings. Id. at 16–19. First, Petitioner argues that a person having ordinary skill in the art would have looked to Cosper as a way to further Izumi’s objective of having a sensor that detects the and controls the movement of the moving element. Id. at 16–17. Second, Petitioner argues that the combination of Izumi and Cosper would have enhanced reliability of the feedback sensors by capturing “data specific to different operating parameters.” Id. at 17–18. Third, combining the references’ teachings would “facilitat[e] implementation of software instructions” by using a microprocessor and memory. Id. at 18–19. Patent Owner does not dispute Petitioner’s rationale to combine the references’ teachings. Based on our review and consideration of the record, we determine that a preponderance of the evidence supports that a person of ordinary skill in the art would have combined the teachings of Izumi and Cosper in the manner Petitioner argues (“the Izumi-Cosper combination”).” slip op. at 17

    Patent outcomesUS 8,093,767 unpatentable
    Claim construction§ 103 obviousnesscites KSR · Graham
    Patents in suitUS 8,093,767
  • PTAB · Oct 9, 2025 · IPR2024-00697 · APJ Brian D Range · IPR · Final written decision

    Claims 1–5 are unpatentable under § 103 based on the combinations of prior art listed in the decision.

    RulingsFinal written decision
    • Skill levelSkill level petitioner adoptedDecided for petitioner

      “physics, or a related technical field, and at least 2–3 years of experience related to the design or development of systems incorporating linear actuators; additional years of experience could substitute for the degree. Pet. 4 (citing Ex. 1003 ¶ 30–31). Patent Owner contends a POSITA would have had (1) a bachelor’s degree in electrical engineering, mechanical engineering, or a comparable field of study, and (2) at least two years of professional experience with electro-mechanical control systems, or other similarly relevant industry experience. PO Resp. 2–3. Additional relevant industry experience may compensate for lack of formal education or vice versa. Id. Patent Owner further contends this is similar to Petitioner’s POSITA contention and states that “Patent Owner does not believe that any of the arguments herein would change if the Board were to adopt Petitioner’s definition for the level of ordinary skill rather than Patent Owner’s.” Id. at 3. For purposes of this Decision, we adopt Petitioner’s proposal as reasonable and consistent with the ’767 patent specification and the prior art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art). Our reasoning herein would be the same under Patent Owner’s similar proposal.” slip op. at 9

    • Claim Construction › Intrinsic evidence (Phillips canons) › Preamble limiting or notPreamble limitingDecided for petitioner

      “Claim 1, Preamble. Both parties agree that the preamble of claim 1 is limiting. Pet. 6; PO Resp. 6. We agree that claim 1’s preamble is limiting. We also note that the parties agreed that this preamble is limiting in the District Court case. Dist. Ct. Const. 10.” slip op. at 10

    • Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededDecided for petitioner

      “Because neither party asserts that construction of “driving component” or “control component” is necessary to resolve the issues before us, we decline to expressly construe these claim terms. See, e.g., 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)). For clarity, because Petitioner argues that plain and ordinary meaning is appropriate and because Patent Owner does not dispute that construction, we adopt the plain and ordinary meaning of these claim terms when comparing the challenged claims to the prior art. Other claim terms. It is unnecessary for us to expressly construe other claim terms for purposes of this Decision. See, e.g., Realtime Data, LLC, 912 F.3d at 1375.” slip op. at 10

    • Obviousness (§103) › Analogous artAnalogous artDecided for petitioner

      “Our reviewing court has stated that “[t]wo separate tests define the scope of analogous prior art: (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) (citations and internal quotes omitted). While these two criteria are helpful in many instances, we must not lose sight of the key question at hand: what is “prior art” as that term is used in 35 U.S.C. § 103(a)? References that are “too remote to be treated as ‘prior art’” are excluded from the obviousness analysis. In re Sovish, 769 F.2d 738, 741, 226 (Fed. Cir. 1985). The non-analogous art test provides helpful insight on the underlying question of what is “prior art” within the meaning of the statute; we should not, however, be blind to the reality of the circumstances of the case before us. In re Wood, 599 F.2d 1032, 1036 (CCPA (1979). Nor should we adhere to rigid and mandatory formulas that overly limit the inquiry. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 419 (2007).” slip op. at 20

    Patent outcomesUS 8,093,767 unpatentable
    Claim construction§ 103 obviousnesscites KSR · Graham
    Patents in suitUS 8,093,767
  • PTAB · Oct 3, 2025 · IPR2025-00680 · APJ Karl D Easthom · IPR · Institution

    The Board instituted IPR of claims 2 and 3 on all grounds in the Petition and granted Nintendo’s motion to join IPR2024-00807, subject to participation limits.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted

      “II. ANALYSIS A. Institution of Inter Partes Review We instituted an inter partes review in the Apple IPR on all challenged claims and all asserted grounds of unpatentability. Apple IPR, Paper 10 (institution decision); see also Apple IPR, Paper 2 (the “Apple Petition”). Petitioner here challenges the same claims and asserts the same grounds of unpatentability as those on which we instituted the Apple IPR. Compare Pet. 2, with Apple Petition 1; see also Mot. 1 (asserting the instant “Petition is substantively identical to Apple Inc.’s petition (‘Apple Petition’) in the Apple IPR, including that it relies on the same expert declaration,” and asserting “the same grounds presented in the Apple IPR”). As indicated, Petitioner also relies on the same declarant as did the petition in the Apple IPR. Mot. 1; compare Ex. 1003 (Hannaford Declaration), with Apple IPR, Ex. 1003 (same). Because the grounds of unpatentability in the instant Petition are identical to those in the Apple IPR and for the same reasons stated in our Decision to Institute in the Apple IPR, we institute inter partes review in this proceeding on the grounds presented in the Petition. See Apple IPR, Paper 10 (analyzing challenges in the Apple Petition).” slip op. at 7

    • PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted

      “We determine that Petitioner has met its burden of showing that joinder is appropriate because, as set forth above, the Petition (1) is substantially identical to the Apple Petition, (2) contains the same grounds based on the same evidence, and (3) relies on the same declaration, the Hannaford Declaration (Ex. 1003). Mot. 1, 4. Petitioner represents that “joinder will not negatively impact the Apple IPR trial schedule” and “expressly consents to the existing trial schedule.” Id. at 10; see also id. at 7 (“Proceeding with a consolidated inter partes review would avoid potential inconsistency, promote efficient review of the same claims for the same patent under the same grounds, and would result in a final written decision without delay.”). Petitioner also represents that as “long as Apple remains in the joined IPR, Nintendo remains in a limited ‘silent understudy’ role that does not actively participate in the IPR.” Id. at 8. The record supports Petitioner. In addition, the final written decision in the Apple IPR is due to issue on or before October 15, 2025, with the Oral Hearing complete and no further briefing due. See IPR 2024-00807, Paper 15 (Oral Hearing Transcript); Paper 18, 2–3. Therefore, as Petitioner argues, joinder by Petitioner will have little or no impact on the trial schedule in the Apple IPR. On the other hand, if the Board denies joinder, Petitioner submits that it “intends to file a separate petition for IPR (‘Second Petition’) that includes grounds in addition to some (or all) of the grounds in the Apple IPR.” Mot. 14.” slip op. at 10

    None
    Patents in suitUS 8,860,337
  • PTAB · Jul 24, 2025 · IPR2024-00222 · APJ Garth D Baer · IPR · Final written decision

    Claims 1–3, 6–23, and 25–33 are unpatentable, including as anticipated by Chen and as obvious over the Chen and Inskeep combinations.

    RulingsFinal written decision
    • Skill levelSkill level patent owner adoptedDecided for patent owner

      “have at least a Bachelor’s Degree in Electrical Engineering and at least two years of experience in the field of electrical engineering and specifically power supply management such as battery charging system design.” PO Resp. 31. Petitioner presents a similar formulation. Pet. 10. Although we do not discern any meaningful distinction between the parties’ formulations, we adopt Patent Owner’s description of a person of ordinary skill as it is consistent with the prior art and challenged patent’s specification. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (prior art itself may reflect an appropriate level of skill).” slip op. at 5

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

      “a first current through one or more output ports of the at least one output port in a first operating mode,” and “is configured to output a second current capable of starting a vehicle engine through the pair of output terminals in a second operating mode.” Ex. 1001, 8:25–34. Claim 21 has similar first and second operating-mode limitations. Id. at 9:40–46. Patent Owner proposes that “[t]he proper construction for ‘first operating mode’ is ‘an operating mode of the portable backup charger wherein the battery pack is configured to output a first current through one or more output ports of the at least one output port, and outputting a second current capable of starting a vehicle engine through the pair of output terminals is inhibited.’” PO Resp. 25. Similarly, Patent Owner argues “[t]he proper construction for ‘second operating mode’ is ‘an operating mode of the portable backup charger wherein the battery pack is configured to output a second current capable of starting a vehicle engine through the pair of output terminals, and outputting a first current through one or more output ports of the at least one output port is inhibited.’” Id. at 27. Patent Owner asserts that claim differentiation supports its construction because dependent claim 3 recites “a third operating mode for outputting the first current and the second current simultaneously,” and “if the battery pack could output the first current and the second current simultaneously in the first operating mode, then there would be no difference between the claimed first operating mode and the claimed third operating mode.” Id. at 26. We disagree with Patent Owner’s constructions because, as Petitioner explains, they wrongly import current-inhibiting limitations beyond the plain language in the claim. Pet. Reply 1. Nothing in the at-issue language addresses inhibiting current. In addition, the claimed first and third operating modes are still distinct without importing additional limitations because outputting just the first current is sufficient for the first operating mode, but not for the third. In other words, whereas the third operating mode requires simultaneity, the first and second merely permit it. Thus, claim differentiation does not support Patent Owner’s construction. Last, although Patent Owner asserts that its construction “is consistent with the specification,” nothing in the cited passages describes inhibiting current. Prelim. Resp. 26 (citing Ex. 1001, 4:30–33, 5:30–33, 5:58–62). Instead, the specification characterizes the modes solely by what the portable charger “can output,” not what is inhibited. Ex. 1001, 4:30–33, 5:30–33, 5:58–62. Thus, we decline to read the first and second operating modes to require the current-inhibiting features that Patent Owner asserts.” slip op. at 6

    • Novelty / Anticipation (§102) › Anticipation standard (single reference, every element)UnpatentableUnpatentable

      “Patent Owner argues the two current paths are not different because Chen’s Figure 1 shows they overlap between the lithium battery and the output control circuit and “only diverge when making the connection to the output control circuit.” PO Resp. 32. We disagree. First, Patent Owner’s argument is based on a claim construction for “different” current paths that we do not adopt for the reasons above. In addition, we agree with Petitioner that Chen shows the claimed different current paths even under Patent Owner’s construction. Pet. Reply 8–12. Specifically, as Petitioner explains, a skilled artisan would recognize that Chen’s physical circuits are depicted in Figures 4–7, rather than in Chen’s Figure 1, which is merely a “block diagram of the principle of present invention.” Id. at 9; Ex. 1006 ¶ 15. Unlike Figure 1, Chen’s Figures 5, 6, and 7 show current paths between the battery and USB outputs, and between the battery and DC multi-gear output, that do not overlap with the high current path shown in Chen’s Figure 4. Pet. 9–12. Based on Petitioner’s analysis and for the reasons above, we agree with Petitioner that Chen teaches the claimed “pair of output terminals coupled to the battery pack and having a current path to the battery pack different from that of the at least one output port to the battery pack.”” slip op. at 10

    • Obviousness (§103) › Motivation to combine / reasonable expectation of successUnpatentableMotivation foundUnpatentable

      “Patent Owner asserts one skilled in the art would not have added White’s fuse to Chen because doing so was “unnecessary” given Chen’s built-in relay K1 that already provides protection. PO Resp. 42–43. We disagree because, as Petitioner notes, “the Petition cited ample evidence that both layers of over current prevention provide improved safety and protection to the battery.” Pet. Reply 17 (citing Pet. 31–33); see also, e.g., Pet. 31 (describing “advantageously reduc[ing] the likelihood of damage”), id. at 32 (describing “the additional benefit of a safety fuse along a jumper cable to promptly cut off current in the event of a short circuit” and “more simplified maintenance and repair”). Given Petitioner’s unrebutted rationale, Petitioner has articulated sufficient reasoning with rational underpinning to support the legal conclusion that adding White’s fuse and polarity-protection connector to Chen’s power-supply system would have been obvious to one of ordinary skill in the art. See KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007). Other than the arguments addressed above, Patent Owner does not additionally challenge Petitioner’s obviousness showing based on Chen and White. We have reviewed Petitioner’s arguments and evidence and, based on that analysis, we find Petitioner has shown by a preponderance of the evidence that claims 1, 2, 6–9, 11–14, 16–22, 25–28, and 30–33 would have been obvious over Chen and White.” slip op. at 15

    Patent outcomesUS 9,643,506 unpatentable
    Claim construction§ 102 anticipation§ 103 obviousnesscites KSR
    Patents in suitUS 9,643,506
  • PTAB · Jul 17, 2025 · IPR2025-00359 · APJ Avelyn M Ross · IPR · Institution

    The Board instituted review of claims 1–4 and 7–17 on all petition grounds and granted Samsung’s unopposed motion for joinder in IPR2024-01013.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted

      “We instituted review of claims 1–4 and 7–18 of the ’483 patent in IPR2024- 01013 after a review of all arguments and evidence presented by the parties, including Patent Owner’s arguments in its preliminary response. For the reasons discussed in the Institution Decision in IPR2024-01013, we determine that Petitioner demonstrates a reasonable likelihood of showing at least one claim of the ’483 patent is unpatentable. Thus, we find that the Petition warrants institution of inter partes review on all claims and grounds set forth in the Petition.” slip op. at 8

    • PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted

      “Upon consideration of Petitioner’s arguments, we are persuaded that it is appropriate under these circumstances to join Petitioner to the proceeding in IPR2024-01013. Petitioner’s agreement to accept an “understudy” role and to not actively participate in IPR2024-01013 unless the current petitioner ceases to participate will limit any potential impact on the trial schedule and will avoid increasing the costs or complexity of the proceeding. Therefore, joinder of Petitioner to IPR2025-00359 will further the goals of a just, speedy, and inexpensive resolution of Petitioner’s challenge. 37 C.F.R. § 42.1(b).” slip op. at 10

    Nonecites Phillips · KSR · Graham
    Patents in suitUS 10,153,483
  • PTAB · Jul 17, 2025 · IPR2025-00358 · APJ Julia Heaney · IPR · Institution

    The Board instituted review of claims 1–16 on all petition grounds and granted Samsung’s motion to join IPR2024-01012 as an understudy petitioner.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted

      “A. Whether the Petition Warrants Institution As we note above, the Petition challenges the same claims on the same grounds of unpatentability, and relies on the same evidence, including the same declarant testimony, as presented in the 1012 IPR. Pet. 1; Mot. 6– 7. In other words, the Petition is virtually identical to the petition filed in the 1012 IPR. We incorporate our analysis from the 1012 IPR regarding the asserted grounds of unpatentability and determine that Petitioner has demonstrated sufficiently under 35 U.S.C. § 315(c) that institution of an inter partes review is warranted under 35 U.S.C. § 314(a).” slip op. at 4

    • PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted

      “Based on the facts and circumstances discussed above, we determine Petitioner has established good cause for joining the 1012 IPR. Specifically, we find that joining Petitioner to the 1012 IPR is unlikely to require any delay or modification to the scheduling order already in place for the 1012 IPR. We also determine that Patent Owner will not be prejudiced unduly by the joinder of this proceeding. Thus, we determine that granting the Motion for Joinder under these circumstances would help “secure the just, speedy, and inexpensive resolution” of these proceedings. See 37 C.F.R. § 42.1(b). For the above reasons, we grant Petitioner’s Motion for Joinder and join Petitioner as a party to the 1012 IPR.” slip op. at 6

    None
    Patents in suitUS 10,608,282
  • PTAB · Jul 17, 2025 · IPR2025-00355 · APJ Julia Heaney · IPR · Institution

    The Board instituted inter partes review of claims 1–23 on the petition’s grounds and granted Samsung’s motion to join the LGES IPR in an understudy role.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted

      “A. Whether the Petition Warrants Institution As we note above, the Petition challenges the same claims on the same grounds of unpatentability, and relies on the same evidence, including the same declarant testimony, as presented in the 1005 IPR. Pet. 1; Mot. 5. In other words, the Petition is virtually identical to the petition filed in the 1005 IPR. We incorporate our analysis from the 1005 IPR regarding the asserted grounds of unpatentability and determine that Petitioner has demonstrated sufficiently under 35 U.S.C. § 315(c) that institution of an inter partes review is warranted under 35 U.S.C. § 314(a).” slip op. at 4

    • PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted

      “Based on the facts and circumstances discussed above, we determine Petitioner has established good cause for joining the 1005 IPR. Specifically, we find that joining Petitioner to the 1005 IPR is unlikely to require any delay or modification to the scheduling order already in place for the 1005 IPR. We also determine that Patent Owner will not be prejudiced unduly by the joinder of this proceeding. Thus, we determine that granting the Motion for Joinder under these circumstances would help “secure the just, speedy, and inexpensive resolution” of these proceedings. See 37 C.F.R. § 42.1(b). For the above reasons, we grant Petitioner’s Motion for Joinder and join Petitioner as a party to the 1005 IPR.” slip op. at 6

    None
    Patents in suitUS 9,636,649
  • PTAB · Jul 17, 2025 · IPR2025-00356 · APJ Grace Karaffa Obermann · IPR · Institution

    The Board instituted review of claims 1–8 on all petition grounds and granted Samsung’s unopposed motion to join IPR2024-01006.

    RulingsInstitution decision
    • PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted

      “We agree with the parties that the Samsung Petition “involves the same patent, challenges the same claims, relies on the same expert declaration, and is based on the same grounds and combinations of prior art.” Id. (Patent Owner’s admission); see Mot. 3 (Petitioner, averring that the Samsung Petition and the Petition filed in IPR1006 are “substantively identical”). Under these circumstances, our reasons for instituting review based on LG Energy Solution’s Petition apply with equal force to the “substantively identical” Samsung Petition. Id. Accordingly, for the same reasons set forth in the Institution Decision filed in IPR1006, we institute review on all claims and all grounds asserted in the Samsung Petition. See generally IPR1006, Paper 8 (Institution Decision in IPR1006).” slip op. at 3

    • PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted

      “(1) the Motion for Joinder is timely, having been “filed within one month of the institution decision” in IPR1006; (2) the Samsung Petition “is substantially identical to the” Petition filed in IPR1006; (3) “joinder will have minimal, if any, impact on the trial schedule, as all issues are substantively identical”; (4) Petitioner agrees to “accept an ‘understudy role’” in the joined proceeding, unless LG Energy Solution, Ltd. “is terminated from” IPR1006; and (4) joinder will simplify “briefing and discovery” as all issues will be resolved “in a single proceeding.” Mot. 3–4. Patent Owner contests none of those facts. To the contrary, Patent Owner does “not oppose” the Motion for Joinder and “fully expects this proceeding to be joined with” IPR1006. Waiver 1. Having considered Petitioner’s Motion for Joinder, as well as Patent Owner’s Waiver, we determine that joinder of the instant proceeding with IPR1006 is appropriate. Accordingly, we grant Petitioner’s unopposed Motion for Joinder, subject to the requirements set forth in the Order below.” slip op. at 4

    None
    Patents in suitUS 8,808,909
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