throbber
Trials@uspto.gov
`571-272-7822
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`
`
`
`Paper No. 28
`Entered: March 10, 2023
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`SAMSUNG ELECTRONICS CO., LTD., DELL TECHNOLOGIES INC.,
`and ANKER INNOVATIONS LTD.,
`Petitioner,
`
`v.
`
`MYPAQ HOLDINGS LTD.,
`Patent Owner.
`______________
`
`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
`______________
`
`Record of Oral Hearing
`Held: February 24, 2023
`_______________
`
`
`
`Before KRISTINA M. KALAN, DANIEL J. GALLIGAN, and
`ELIZABETH M. ROESEL, Administrative Patent Judges.
`
`
`
`
`
`
`
`
`
`

`

`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`ELIOT D. WILLIAMS, ESQ.
`BRETT THOMPSEN, ESQ.
`Baker Botts LLP
`700 K Street NW
`Washington, DC 20001
`(202) 639-1334 (Williams)
`eliot.williams@bakerbotts.com
`brett.thomsen@bakerbotts.com
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`STEPHEN McBRIDE, ESQ.
`JAMES T. CARMICHAEL, ESQ.
`MINGHUI YANG, ESQ.
`Carmichael IP, PLLC
`8000 Towers Crescent Drive
`Floor 13
`Tysons Corner, Virginia 22182
`(703) 646-9255 (Carmichael)
`(703) 646 9247 (McBride)
`(703) 646-9248 (Yang)
`jim@carmichaelip.com
`stevenmcbride@carmichealip.com
`mitch@carmichaelip.com
`
`
`
`
`The above-entitled matter came on for hearing on Friday, February
`
`24, 2023, commencing at 1:00 p.m. EST, via Video-conference.
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`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
`
`
`P R O C E E D I N G S
`- - - - -
`
` (1:00 p.m.)
`JUDGE GALLIGAN: Good afternoon. This is Administrative
`
`Patent Judge Galligan. With me are Judges Kalan and Roesel. This is a
`consolidated oral argument for IPR 2022-00311 and IPR 2022-00312. The
`patents are 8,477,514 B2 and 7,675,759 B2. The Petitioner is Samsung
`Electronics Company, Ltd., Dell Technologies, Inc. and Anker Innovations,
`Ltd. Patent Owner is MyPAQ Holdings. May we have appearances for
`counsel starting with Petitioner, please?
`
`MR. THOMPSEN: Yes, Your Honor. This is Brett Thompsen. I am
`backup counsel for Petitioners, and I will be doing the presenting today. On
`the line with me is lead counsel, Eliot Williams, and also on the public line
`are the other backup counsel and representatives from both Samsung and
`Dell.
`JUDGE GALLIGAN: Thank you, and Patent Owner?
`
`MR. MCBRIDE: This is Steve McBride for Patent Owner, MyPAQ
`
`Technologies. With me is James Carmichael, to my left here, who is lead
`counsel in this matter. Also on the public line may be representatives of
`MyPAQ, as well as Mitch Yang is also of record and a few other attorneys
`for MyPAQ.
`
`JUDGE GALLIGAN: Thanks for that. Anker Innovations is a
`Petitioner that filed a Motion for Joinder, and we understand that counsel for
`Anker will not be presenting. If they’re on the line, they may make an
`appearance, but I’ll give them a moment. All right, thank you. Sorry, is
`someone speaking? Thank you. As set forth in the Oral Hearing Order, each
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`IPR2022-00312 (Patent 7,675,759 B2)
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`party has 90 minutes of argument time to cover both proceedings. Our first
`priority is your right to be heard, so if at any time during the hearing you
`encounter technical or other difficulties you feel undermine your ability to
`adequately represent your client, please let us know immediately.
`You may do this by contacting the team who provided you with the
`connection information. If you stop hearing or drop off, please note what was
`being discussed and we’ll try to pick up from there. Please mute your
`microphone and only unmute when speaking. Identify yourself when you
`speak so the transcript accurately reflects the speaker. When referring to an
`item in the record, please do so with specificity, slide number and paper
`number, exhibit number, etc. Because we have two cases, please refer to the
`case number when you’re referring to an item in the record. As to the public
`line, we’re not aware of any confidential information. That shouldn’t be a
`problem.
`Petitioner, you’ll go first. You may reserve some time for rebuttal.
`Would you like to reserve any time?
`MR. THOMPSEN: Yes, Your Honor. I’d like to reserve 30 minutes.
`JUDGE GALLIGAN: Okay. And let me see, so I’ll try to give you a
`heads up a little before the hour. Let me just get my stopwatch going, and
`you may begin.
`MR. THOMPSEN: Thank you, Your Honor. As Your Honor noted,
`the 311 IPR involves US Patent 8,477,514 and the 312 IPR involves US
`Patent 7,675,759. The 514 patent is a continuation of a continuation in part
`from the 759 patent, so these two patents involve overlapping specifications,
`overlapping disclosures. Today when I’m speaking about the patent or the
`specification, I’ll be speaking to both. If I intend to speak to one or the other,
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`IPR2022-00312 (Patent 7,675,759 B2)
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`I’ll make sure to point that out. If we could go to Slide 3 of Petitioner’s
`demonstratives, here’s a listing of the various issues that were raised in the
`papers.
`I certainly don’t intend to speak to all of those issues within the hour,
`but what I’d like to do is start with a brief overview of the 514 and 759
`patents, as well as the prior art grounds, and then speak to issues in three
`different buckets. I’d like to speak to two issues in the first bucket, because
`they’re issues that are common to both the 311 and the 312 IPR, as well as
`issues in the second bucket. Those are issues specific to the 311 IPR. I’ll
`speak to two issues in that second bucket. Then also two issues in the third
`bucket involving the 312 IPR and the 759 patent.
`As I step through these various issues, we’ll notice a theme. That
`theme is that the issues often don’t revolve around the actual disclosures in
`the prior art. They revolve around narrowing constructions the Patent Owner
`raises in an effort to try to carve out that prior art. But as we’ll see, those
`narrowing constructions conflict with the plain meaning of the claims and
`also often conflict or improperly exclude embodiments in the 514 and 759
`patents. So if we stick with the plain meaning of the claims consistent with
`the patent specification, the prior art meets each of the challenged claim
`limitations.
`So let’s go to Slide 5, and I’ll start with a brief overview of the
`challenged patents. So these challenged patents involve switching power
`converters, and so you’ll see the power converter on the left, it includes two
`switches. Those switches will turn off perhaps thousands, hundreds of
`thousands of times per second. That’s how energy is transferred from the
`input to the output of the power converter. Now it was well known in the art,
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`as well as described in the background of the patents, that the duty cycle of
`those switches can be controlled to regulate the output voltage.
`Well, what the patent purports to do is to purportedly improve upon
`the prior art by adjusting internal characteristics, such as the switching
`frequency of the power converter, based on a signal that’s external from the
`power converter. For example, a signal indicating the system operational
`state of the load. So the patent purports to use the signal from the load to then
`change the power converter’s own internal operating states in order to
`improve efficiency of the power converter. But as you’ll see, the prior art
`also discloses that concept. If we go to Slide 6, there’s an overview of the
`invalidity grounds, the 311 IPR involves the Chagny and Hwang references
`as prior art. And then the 312 IPR also involves Chagny and Hwang, but then
`adds the additional reference, the Hirst reference.
`We go to Slide 7, we see the Hirst reference. Hirst discloses a power
`converter that’s used in a printer. Hirst tells us that when the printer is
`printing and it’s in its normal mode of operation, that can be signaled to the
`power converter to operate at its highest switching frequency state. On the
`other hand, when the printer is in standby, for example when there’s no data
`being printed, that can be signaled to the power converter to operate at its
`lower frequency state. So much like the patents at issue, Hirst discloses
`controlling the states of the power converter based on the system’s
`operational state of the printer.
`Let’s go to Slide 8 next. Here’s the Chagny reference. Chagny is a Dell
`patent that, much like embodiments in the specification of the 514 and 759,
`provides power to a processor. Again, Chagny looks at the operating state of
`that processor, and that is signaled to the power converter to change the
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`power converter’s own operational states. Going to Slide 9, there’s the
`Hwang reference. Hwang also includes a microprocessor as the load for the
`power converter. That microprocessor can go into normal operating modes or
`it can go into a standby mode. And just like the other patents, those different
`modes, those different system operational states of the microprocessor, can
`be signaled to the power converter to tell the power converter to go into
`different power converter operational states.
`So with that overview in mind, I’d like to jump into the first of the
`issues that are common to both the 311 IPR and the 312 IPR. That is the
`concept of a system operational state of load. We go to Slide 11, see that this
`term is involved in Claim 1 of the 514 patent, as well as Claims 1, 6, and 16
`of the 759 patent. Go to Slide 12, we can see it’s recited. For example, in
`Claim 1 of the 514 patent, it recites a power converter controller configured
`to receive a signal from said load indicating a system operational state of said
`load.
`
`Here the power converter is receiving a signal from the load that
`indicates the system operational state of the load. Now on the 759 patent, the
`claims don’t recite where the signal originates from, but it still recites a signal
`indicating the system operational state of the load. So with this term, there
`are three things that I want to touch on. First, I want to talk about the
`background section of the patent, because this is going to frame how this
`term, how the system operational state of load, actually fits within the
`perceived invention of the patent. And that will help us understand what this
`term, system operational state of the load, actually means.
`Next, I’ll step through the prior art and show how the prior art actually
`corresponds to examples in the 759 and 514 patent. And then three, I want to
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`address Patent Owner’s narrowing construction that they raised in their
`papers and how that narrowing construction improperly excludes
`embodiment from the patent specification itself. So let’s go to Slide 13. So
`Slide 13, I’ve got listed three different snippets. These are all from the
`background section of both the 759 and the 514 patents. It starts by stating
`power conversion systems of the prior art have only partially responded to
`such system operational state considerations. It then describes P-states and C-
`states of a processor as examples of those system operational state
`considerations.
`Now on the next snippet you see on Slide 13, the patent states that
`although these state indicators have been used to substantially reduce the
`energy requirement of a digital system, that’s the processor, similar
`corresponding states on the power converter side haven’t been used to help
`the efficiency on the power converter side. So the patent states accordingly,
`opportunities for further improvement in power converter operational
`efficiency have not been realized. And then at the end of the background
`section, the patent states that what is needed is a controller for a power
`converter that adaptively improves power conversion efficiency of a power
`converter in response to the system operational state of the load.
`So what this tells the POSITA is that a system operational state of the
`load isn’t necessarily new. This is something, for example, the P-state or C-
`states of a processor. What was purportedly new in the patents was how that
`those P-states or C-states were then used to signal the power converter so that
`efficiency could be optimized on the power converter side. But of course, the
`prior art discloses that, as well. Go to Slide 14, we can see how this plays out
`in the heart of the patent. In the top quote from Slide 14, we see that the
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`patents state a power converter provides power to a system such as a
`microprocessor coupled to an output of that power converter. The patent then
`goes on to refer to different power converter operational states that may be
`enabled upon receipt of a system operational state, such as a processor core
`state.
`
`So again, in the heart of the patent it’s describing these known core
`states of a processor as the system operational state of the load, but then it’s
`indicating that that core state is being signaled to the power converter so the
`power converter can change its operational efficiency. So let’s go next to
`Slide 15, and we see the Chagny reference. Chagny, as I mentioned earlier,
`includes a processor on the load. That’s highlighted in red on the left of Slide
`15. Chagny also includes a software program 296 that monitors the processor
`loading and specifically the activity level of that processor.
`So the software program is monitoring the system operational state of
`that processor load and then generates the activity input signal 202. That
`signal is highlighted in purple towards the bottom left of Figure 2A. So that
`signal 202 is the signal indicating system operational state of the load. As we
`go to Slide 16, there are analogies between Chagny and the disclosures in the
`514, as well as the 759 patents. As we mentioned earlier, the C state of a
`processor is a example of a system operational state of a load, and those C-
`states describe different operational levels. For example, different C-states,
`including various P-states, can be achieved by halting instruction execution.
`That’s the same thing that Chagny tells us. Chagny discloses that
`processor 292 in its activity level will depend on the number of instructions
`executed in a given amount of time. So Chagny, much like the examples in
`the 514 and 759 patents, describes this activity level and that serves as a
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`IPR2022-00311 (Patent 8,477,514 B2)
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`signal indicating a system operational state of Chagny’s processor load. Now
`going next to Slide 17, I want to address Patent Owner’s argument regarding
`this term. So faced with the Chagny prior art and other references, Patent
`Owner has come up with the argument that system operational state must
`indicate a “particular context beyond just the current or future operational
`state of the load.”
`Now in a moment, I’ll explain why that particular context requirement
`1) finds no support in the claims, and 2) actually improperly excludes various
`embodiments in the specification. But first I want to look at Patent Owner,
`what they said in district court, because it shows they’ve changed their
`position over time. In district court, Patent Owner stated that a system
`operational state—and I’ll be clear, Patent Owner proposed this construction
`and actually preliminarily won this construction in district court—and Patent
`Owner proposed that a system operational state of a load should mean an
`operational condition of the load with the only proposed caveat being one
`that it doesn’t apply here to the prior art.
`That only caveat being that the operational condition of the load must
`be more than just the output voltage provided by the power converter to the
`load. So essentially what we have here if we put that caveat aside because it
`does not apply to the prior art in this IPR, Patent Owner argued in district
`court that a system operational state of a load is simply the operational
`condition of the load, which is very much the opposite of what they argue
`now, that there must be this additional particular context beyond just the
`current or future operational condition of the load.
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`Of course we know that Patent Owner’s particular context is also
`wrong because it finds no support either in the claims or the specification.
`We go to Slide 18, we see a printout of the claims again.
`JUDGE GALLIGAN: This is Judge Galligan. I just wanted to ask a
`quick question about Slide 17. I noticed the preliminary claim construction,
`which is an exhibit, Patent Owner entered it in both proceedings and it was
`an email from the clerk of the court in the Western District of Texas. Has
`there been a final claim construction determination?
`MR. THOMPSEN: There has not yet been a final determination of this
`case. That district court case was stayed once the IPRs were instituted.
`JUDGE GALLIGAN: Thanks.
`MR. THOMPSEN: Thank you, Your Honor. So going back to Slide
`18, again we see the claim language printed again. Every time the claims
`introduce the concept of a system operational state, it refers to a system
`operational state of said or of a load. So the plain language dictates that the
`system operational state is a state of the load, not a state external or regarding
`some particular context outside of the load. What I’m going to talk about
`next is the specification. So as we noted before, the C-state and P-states of a
`processor are given as examples of a system operational state of a load. And
`as the ACPI specification states or shows, those are just states of the
`processor itself, not necessarily indicating external conditions to the
`processor that might be the higher level trigger that causes the processor to
`go into that system operational state.
`
`But nonetheless, Patent Owner points to a piece of the specification.
`Now let’s go to Slide 19, Patent Owner points to the top snippet that I have
`on Slide 19 from the patent specification to find alleged support for its
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`IPR2022-00311 (Patent 8,477,514 B2)
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`particular context requirement. That snippet states further examples
`indicating a system operational state include, without limitation, a signal
`providing a performance sate or a core state of a processor such as a P-state
`or C-state. Now the patent does go on to say that those P-states or C-states
`may indicating, for example, and it lists out different conditions. Now those
`are different conditions that the operating system may use to control the
`P-state or the C-state, but those P-states and C-states, those are the system
`operational state of the load of the processor itself.
`
`Indeed, if we look at Patent Owner’s construction, you would actually
`exclude some of the embodiments from the very material that they cited. For
`example, highlighted in blue on Slide 19, there’s an indication of a higher
`level of system performance. Well, a higher level of system performance is
`exactly what a P-state is. A P-state is defined in the patent as a performance
`state of the processor, such as high, medium or low. Likewise, a C-state
`describes the operational level of the processor. So this example that Patent
`Owner actually points to in its bullet points that it lists out in its Patent
`Owner Response actually does not support their construction.
`
`Moreover, Patent Owner’s construction would improperly exclude the
`example that I’ve got highlighted in green. So let’s go to the next Slide 20,
`we see that same example highlighted in green. It states, and this is in both
`the 514 and 759 patent, “an example of a signal indicating a change in a
`system operational state is a signal indicating that a load current will change
`from a first current level to a second current level.” And as Petitioner’s
`expert explained, the load current is simply the electrical current drawn by
`the load. That doesn’t depend on or that doesn’t reflect what the particular
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`context outside of the load is. That just speaks to the load itself and the state
`of the load.
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`So that example provided in the specification would be excluded
`improperly by Patent Owner’s particular context requirement. I want to go to
`Slide 21, as well, and I want to point the Board to different arguments that
`the Patent Owner has made at different times. Now in its Patent Owner
`Response on Pages 6 to 7 of the 311 IPR, as well as on Page 7 of the 312
`IPR, the Patent Owner stated—and this is when the Patent Owner is
`describing just the general disclosure of the patent. When the Patent Owner is
`describing the general disclosures of the patent, the Patent Owner readily
`admits, “another system operational state is the core state or C-states.”
`Patent Owner then goes on to quote the patent to describe core state or
`C-states as different operational levels. However, when the Patent Owner is
`trying to later carve out the prior art, such as Chagny and Hwang, Patent
`Owner says that the 514 patent expressly distinguishes C-states from the
`system operational states. But again, this is not true. What the background of
`the patent is distinguishing is not a C-state or a core state, but how that C-
`state or core state, which are examples of system operational states, how
`those are used to signal the power converter to update the power converter’s
`own operational state.
`So unless the Board has questions about Chagny, I want to point to
`Hwang briefly. Hwang is shown on Slide 23. We see Hwang has load 104
`that’s provided power by the power converter, which is highlighted here in
`blue. Hwang states that the load 104 may include a microprocessor that may
`enter a standby mode during periods of low activity or non-use. So Hwang’s
`microprocessor, or they also describe it as a controller, can operate in either a
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`normal mode of operation or a standby or what it refers to as a sleep mode of
`operation. So these different modes of operation are the system operational
`state of the load, and when those change, Hwang’s load 104 also sends a
`signal, which is highlighted in purple on Slide 23, back to the power
`converter controller to update the power converter controller’s operation.
`Moving next to Slide 26, we see the Hirst reference, and although this
`issue of system operational state of a load is common to both IPRs, Hirst
`itself is specific to the 312 IPR. We see Figure 1 of Hirst on the left of Slide
`26. That includes a multiple-frequency switching power supply that’s
`highlighted in blue, and that provides power to different portions of the
`printer, including the data input port 14, the memory 16, and the print engine
`20. Hirst states that during normal operation of the printer, the power
`consumption monitor 22 detects normal power consumption. But when no
`data is present at the data input port and the printer is not active, the power
`consumption monitor will detect reduced power consumption.
`So the words of Hirst itself equates what is monitored by the power
`monitor to the system operational state of the printer, that’s either actively
`printing in normal operation or in standby mode when there’s no printing
`occurring. Then accordingly, the power monitor generates a signal that we’ve
`highlighted here in purple on Slide 26, and that’s the signal indicating the
`system operational state of that printer load. Unless the Board has questions
`about system operational state, I’d like to move to another topic that’s
`common to both the 311 and the 312 IPR, and that is the control of duty
`cycle.
`If you go to Slide 30, we see that the duty cycle is recited in Claims 2,
`7, 12 and 17 of the 514 patent. That’s one dependent claim in each of the
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`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
`
`claim sets of the 514 patent, as well as in each independent claim of the 759
`patent, Claims 1, 6 and 16. Go to Slide 31, we see a reproduction of that
`claim language. For example, in Claim 2 of the 514 patent it recites, “to
`provide another signal to control said duty cycle of said power switch as a
`function of said output characteristic,” and then two, “in accordance with said
`signal.” What I’ll note is that the different claims here, they do have slightly
`different language for this in accordance with, but the mapping in the prior
`art is the same, and the dispute between the parties is the same across the
`board.
`So the issue is really uniform across the board with regard to this in
`accordance with language. So as we get into duty cycle, there are three things
`I want to talk about. First is the definition of duty cycle, and second is how
`the prior art discloses the “function of” aspect, and then third, how the prior
`art discloses the “in accordance with” aspect. Before I get into the prior art,
`what I do want to note is that Patent Owner only challenges this element for
`the Chagny and Hwang references that are common to both IPRs. Patent
`Owner does not challenge Hirst’s disclosure of this element in the 312 IPR
`specifically.
`So let’s go to Slide 32, and here’s a snippet from the 514 and the 759
`patent that defines duty cycle. It states quote, “the duty cycle is a ratio
`represented by a conduction period of a power switch to a switching period
`thereof.” If we go over to the left on Slide 32, there’s Figure 3 from the
`patent, and there are different switches in there. For example, Q boost is the
`switch on the far left. As a switching power converter, that switch, for
`example, is going to turn on thousands or even hundreds of thousands of
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`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
`
`times per second. If we zoom in on one switching cycle, what the patent tells
`us is that the duty cycle is represented by the conduction period.
`That’s the on time of a given switching cycle divided by the switching
`period. That’s the sum of the on time and the off time for a given switching
`cycle. So the duty cycle is merely represented based on an equation based on
`the on time and the off time of a switching cycle of that power switch. So
`with that in mind, let’s go to Slide 33 and we have the Chagny reference.
`You see the power converter controller is highlighted in gray. At the top of
`that power converter controller that provides a signal 212, it’s highlighted in
`purple, and that goes to the gate of the power switch 220 that’s highlighted in
`orange.
`Chagny tells us that the signal 212 is turning on and turning off that
`power switch, so that is controlling the on time and off time that’s the basis
`of the duty cycle for that power switch. What Chagny also shows is the
`power converter controller as two different inputs that contribute to that duty
`cycle. First there’s the feedback path. That’s the signal highlighted in red
`coming from the right over to the left into the power converter controller, and
`then there’s also the activity signal 202 that’s highlighted in purple, going
`from the left to the right. So Chagny’s power converter controller takes
`inputs from these two different signals to control the duty cycle. I’ll speak to
`each of those next.
`As I mentioned, Chagny’s signal 212, that controls turning on and off
`the power switch, and it was well known in the art that the duty cycle of that
`power switch is what controls the output voltage. Chagny also states that the
`controller module 210, that’s the power converter controller, receives a
`regulated DC output voltage as the feedback input for regulating the output
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`16
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`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
`
`of the power converter. So what’s happening is this feedback signal
`highlighted in red, that’s received by the power converter controller. The
`power converter controller compares the feedback regarding the actual output
`voltage, compares that to the desired output voltage, and makes any
`adjustments that are necessary to the duty cycle in order to ensure that the
`actual output voltage matches the desired output voltage.
`If we go to Slide 34, on the bottom there’s a quote from the Board’s
`Institution Decision in the 312 IPR, citing the testimony of Petitioner’s
`expert, Dr. Kiaei, noting that, “a person of ordinary skill in the art would
`have understood this feedback mechanism to mean that the switch’s duty
`cycle is also controlled as a function of the feedback from the regulated DC
`voltage output 295 (i.e., as a function of said output characteristic).” That
`continues to be correct today. The only thing Patent Owner has argued is that
`Chagny doesn’t actually use the words duty cycle, but that’s not the pertinent
`question.
`The pertinent question is what a person of ordinary skill in the art
`would understand Chagny to disclose, and that includes control of the duty
`cycle as a function of this feedback from the output. If we go to Slide 35, I’ll
`speak next to how Chagny discloses the “in accordance with” language, and
`specifically how Chagny discloses control of the duty cycle in accordance
`with said command or signal. So for Chagny, the command or signal is the
`signal 202 shown in the bottom left of Figure 2A, and that signal is provided
`to the power converter to set the switching frequency of the power converter.
`So that’s going to set the frequency at which the power switch turns on and
`off. This is inextricably intertwined with the control of the duty cycle.
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`IPR2022-00311 (Patent 8,477,514 B2)
`IPR2022-00312 (Patent 7,675,759 B2)
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`If you recall, the duty cycle defines the conduction period, that’s the on
`time of a switching cycle divided by the switching period, which is the on
`time plus the off time of a switching cycle. The switching period as measured
`in time is just the inverse of switching frequency as measured in hertz. So the
`setting of the switching frequency is going to determine the denominator of
`how you calculate duty cycle. So a person of ordinary skill in the art would
`understand that control of the duty cycle in Chagny is done so in accordance
`with the setting of the frequency, which is going to determine the
`denominator in that duty cycle equation.
`Moving to Slide 37, there’s a depiction of Hwang. I’ll explain how
`Hwang discloses, much like Chagny, control the duty cycle both as a
`function of the output characteristic and in accordance with the command. So
`in Figure 3 of Hwang, highlighted here in blue on Slide 37, there’s the power
`converter output voltage Vout, and there’s a feedback path through a resister,
`R4 and R5, that goes down to the PWM controller 310. PWM control

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