`
`Paper No. 5
`Filed: November 8, 2022
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SHENZHEN APALTEK CO., LTD.,
`Petitioner,
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`v.
`ASETEK DANMARK A/S,
`Patent Owner.
`____________
`
`Case No. IPR2022-01317
`U.S. Patent No. 8,245,764
`____________
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`PATENT OWNER’S PRELIMINARY RESPONSE
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`B.
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`2.
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`2.
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`TABLE OF CONTENTS
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`Preliminary Statement ..................................................................................... 1
`I.
`The “Reservoir” of the Claimed Invention ...................................................... 3
`II.
`III. The Board Should Deny Institution of Grounds 1 and 2 Because Duan
`Does Not Disclose the “Reservoir” Limitation of Independent Claims
`1, 10, and 15 ..................................................................................................... 5
`IV. The Board Should Deny Institution of Ground 5 Under 35 U.S.C. §
`325(d) .............................................................................................................10
`A.
`Part One of The Advanced Bionics Framework ..................................12
`1.
`Becton, Dickinson Factors (a) and (b): The Prior Art
`Cited by Petitioner is the Same Prior Art Considered by
`the Examiner. ............................................................................12
`Becton, Dickinson Factor (d): Substantially the Same
`Arguments Were Previously Considered by The
`Examiner. ..................................................................................13
`Part Two of the Advanced Bionics Framework ..................................13
`1.
`Becton, Dickinson Factor (c): Batchelder Was
`Substantially Evaluated During Examination. ..........................13
`Becton, Dickinson Factors (e) and (f): Petitioner
`Failed to Sufficiently Point Out How the Examiner
`Erred or Why the Evidence and Facts of the Petition
`Warrant Reconsideration. .........................................................13
`Conclusion .....................................................................................................15
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`V.
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`TABLE OF AUTHORITIES
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` Page(s)
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`Cases
`Advanced Bionics, LLC v. MED-EL Elektromedizinische Geräte GmbH,
`IPR2019-01469, Paper 6 (P.T.A.B. Feb. 13, 2020) .....................................passim
`Asetek Danmark A/S v. CMI USA, Inc.,
`100 F. Supp. 3d 871 (N.D. Cal. 2015) .................................................................. 1
`Asetek Danmark A/S v. CMI USA Inc.,
`852 F.3d 1352 (Fed. Cir. 2017) .................................................................... 2, 4, 6
`Asetek Danmark A/S v. CMI USA, Inc.,
`No. 13-CV-00457-JST, 2015 WL 5568360 (N.D. Cal. Sept. 22, 2015) .............. 4
`Asia Vital Components Co. v. Asetek Danmark A/S,
`377 F. Supp. 3d 990 (N.D. Cal. 2019) .................................................................. 2
`Becton, Dickinson & Co. v. B. Braun Melsungen AG,
`IPR2017-01586, Paper 8 (P.T.A.B. Dec. 15, 2017) ............................... 11, 12, 13
`Statutes
`35 U.S.C. § 325(d) ................................................................................... 3, 10, 11, 15
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`LIST OF EXHIBITS
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`
`
`Description
`Exhibit
`Ex. 2001 Decision on Appeal, dated Apr. 29, 2016 in Inter Partes
`Reexamination Control No. 95/002,386.
`Final Verdict Form in Asetek Danmark A/S v. CMI USA, Inc., Case
`No. 3:13-CV-00457-JST (N.D. Cal.)
`Excerpt from the Court’s summary judgment decision in Asetek
`Danmark A/S v. CoolIT Systems, Inc., Case No. 3:19-CV-00410-EMC
`(N.D. Cal.). The entire decision has not been provided in the interest
`of brevity.
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`Ex. 2002
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`Ex. 2003
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`iii
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`I.
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`IPR2022-01317
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`Preliminary Statement
`For more than a decade, Patent Owner Asetek Danmark A/S (“Asetek” or
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`“Patent Owner”) has developed and commercialized liquid cooling devices for
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`desktop computers, servers, and datacenters. Asetek’s pioneering liquid cooling
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`technology created the thriving market for liquid cooling devices and has been used
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`in millions of computers worldwide. U.S. 8,245,764 (“the ’764 patent”) discloses
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`many of Asetek’s technological advances in the art of computer liquid cooling.
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`This IPR petition is the fourth round in a series of invalidity attacks against
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`the ’764 patent claims. In 2012, Asetek’s competitor, CoolIT Systems, Inc., filed an
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`inter partes reexamination (Control No. 95/002,386) challenging the validity of
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`Asetek’s the ’764 patent claims. Following the proceedings in the reexamination unit
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`and an appeal to the Board, all claims of the ’764 patent were confirmed as
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`patentable. Ex. 2001 at 8.
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`The ’764 patent was also found to be not anticipated in a jury verdict in a
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`separate litigation against CMI USA, Inc. (Asetek Danmark A/S v. CMI USA Inc.,
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`Case No. 4:13-CV-00457), in the U.S. District Court for the Northern District of
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`California. Ex. 2002 at 2 (see also page 4 of verdict form, showing that the jury
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`found all asserted secondary considerations in favor of Asetek). The presiding judge
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`in that case also found that the ’764 patent claims were not obvious in view of the
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`prior art asserted by CMI USA. Asetek Danmark A/S v. CMI USA, Inc., 100 F. Supp.
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`1
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`3d 871, 889 (N.D. Cal. 2015) (finding that the ’764 patent is not invalid for
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`obviousness and that “[a]ll six objective indicia of non-obviousness” that the jury
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`found in Asetek’s favor supports the Court’s nonobviousness finding). And the
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`Federal Circuit later affirmed both the jury and the district court’s findings. Asetek
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`Danmark A/S v. CMI USA Inc., 852 F.3d 1352, 1359-62 (Fed. Cir. 2017).
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`In a further litigation against Asia Vital Components Co., Ltd., the same ’764
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`patent was found to be not obvious in summary judgment proceedings. Asia Vital
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`Components Co. v. Asetek Danmark A/S, 377 F. Supp. 3d 990, 1014 (N.D. Cal.
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`2019).
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`Thus, the ’764 patent claims have been repeatedly confirmed as valid in many
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`different fora. In this fourth challenge, Petitioner Shenzhen Apaltek Co., Ltd.
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`(“Petitioner” or “Apaltek”) asserts three grounds (Grounds 1, 2, and 5) against
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`independent claims 1, 10, and 15 of the ’764 patent. The remaining grounds (Ground
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`3, 4, and 6) are only asserted against dependent claims. In Grounds 1 and 2, the
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`Petition asserts that Duan by itself or in view of Duan-I renders independent claims
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`1, 10, and 15 obvious. And in Ground 5, the Petition asserts that Batchelder in view
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`of Duan renders claims 1, 10, and 15 obvious. But as discussed in detail below, Duan
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`fails to disclose a single-receptacle “reservoir,” which is a central feature of the
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`claimed invention and is recited in each of the independent claims. Duan-I, which
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`the Petition uses only for its orientation, does not overcome Duan’s lack of a single-
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`2
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`receptacle “reservoir.” See Pet. at 31-33. Rather than acknowledging Duan’s
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`deficiency, Petitioner and its expert, without support, simply stated that Duan
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`teaches the missing “reservoir” element. But such conclusory assertions cannot
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`support an obviousness finding. The Board should thus deny institution based on
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`Grounds 1 and 2.
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`Additionally, the Board should exercise its discretion under 35 U.S.C.
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`§ 325(d) and deny institution based on Ground 5 (Batchelder in view of Duan). The
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`Examiner already considered Batchelder during prosecution, but nonetheless found
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`the claimed invention allowable. Petitioner does not even acknowledge that
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`Batchelder was considered and applied by the Examiner during prosecution, nor
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`does Petitioner offer any reason or evidence how the Examiner erred. Accordingly,
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`the Board’s precedent dictates that the Petition should be denied.
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`II. The “Reservoir” of the Claimed Invention
`The ’764 patent claims an invention over prior art liquid cooling systems,
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`which were often bulky with many components which increased the total installation
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`time, size, and risk of leakage. Ex. 1001 at 1:37-47. Asetek overcame these problems
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`with a small and compact design that is more efficient, easy to use and implement,
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`and requires a low level of maintenance. Id. at 1:51-60.
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`Asetek’s claimed invention has several notable features, including a
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`“reservoir,” which circulates cooling liquid to keep computer chips from
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`3
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`overheating. See id. at 21:12-22:53. The parties in the related district court litigation
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`(and in prior litigations) construed “reservoir” as a “single receptacle defining a fluid
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`flow path,” and a “chamber” as “compartment within the reservoir.” Pet. at 6.
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`The single-receptacle “reservoir” limitation overcame prior art in the prior
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`litigation against CMI USA. CMI USA Inc., 852 F.3d at 1357–58 (“[T]he jury found
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`that the claimed liquid-cooling systems differ from the prior art . . . because the
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`‘reservoir’ is a ‘single receptacle that is divided into an upper chamber and a lower
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`chamber.’”). Specifically, when Asetek previously asserted the ’764 patent (and the
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`related U.S. Patent No. 8,240,362, which has the same “reservoir” feature) in an
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`infringement action against CMI USA, Asetek argued that the patents were not
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`invalid over the prior art because the “reservoir” limitation required a single
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`receptacle while the prior art disclosed two separate receptacles attached together.
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`Id. at 1356–58. The jury agreed with Asetek and found Asetek’s patents valid. Asetek
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`Danmark A/S v. CMI USA, Inc., No. 13-CV-00457-JST, 2015 WL 5568360, at *2
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`(N.D. Cal. Sept. 22, 2015), aff’d in part, remanded in part, 842 F.3d 1350 (Fed. Cir.
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`2016), opinion modified and superseded on reh’g, 852 F.3d 1352 (Fed. Cir. 2017),
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`and aff’d in part, vacated in part, 852 F.3d 1352 (Fed. Cir. 2017).
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`The drawings of the ’764 patent clearly disclose that the “reservoir” is a single
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`receptacle that includes dual chambers: a “pump chamber” and a “thermal exchange
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`chamber.” See Ex. 1001, Figure 20 (annotated below). As shown below, the
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`“reservoir” shown in green is a single structure that includes a pump chamber 46 and
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`a thermal exchange chamber 47A.
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`Ex. 1001, Fig. 20 (annotations added).
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`III. The Board Should Deny Institution of Grounds 1 and 2 Because Duan
`Does Not Disclose the “Reservoir” Limitation of Independent Claims 1,
`10, and 15
`The Petition provides little explanation of how Duan discloses a single-
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`receptacle “reservoir.” The Petition merely notes that “Duan teaches a reservoir
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`(accommodation chamber 21, cap 3, and cooling plate 1) adapted to pass the cooling
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`liquid therethrough.” Pet. at 34-37. But nowhere does the Petition explain how
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`accommodation chamber 21, cap 3, and cooling plate 1 define a single receptacle;
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`5
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`instead, it is clear from the drawings of Duan that cooling plate module 10 of Duan
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`includes two receptacles—one defined by accommodation chamber 21 and another
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`defined by cap 3 and cooling plate 1—and those two receptacles are simply attached
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`together. See Ex. 1006 (Duan), Figs. 3, 6, and 7 (annotated below). As the Federal
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`Circuit affirmed in CMI USA Inc., two separate receptacles attached together
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`do not form a single receptacle. See 852 F.3d at 1357–58.
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`Ex. 1006, Fig. 3 (annotations added)
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`Ex. 1006, Fig. 6 (annotations added)
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`Ex. 1006, Fig. 7 (annotations added)
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`In Asetek Danmark A/S v. CoolIT Systems, Inc., Case 3:19-CV-00410-EMC,
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`a district court Judge in the Northern District of California (NDCA) similarly found
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`that “[a] receptacle is a structure that receives and contains fluid,” and when two
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`separate structures are attached to form a “reservoir,” the important consideration is
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`not whether the two structures are “permanently affixed” such that their separation
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`would destroy the device or cause fluid leakage, but whether the two structures can
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`“function independently.” Ex. 2003 at PDF pp. 2-3. More specifically, the NDCA
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`Court found that when determining whether two structures form a single-receptacle
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`“reservoir,” the issue is “not whether the device itself would be destroyed if
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`physically taken apart but whether the first and second structures can each function
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`as a receptacle.” See id. at PDF p. 3. Here, it is clear from the drawings of Duan that
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`Duan’s accommodation chamber 21 and the combination of cap 3 and plate 1 can
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`function independently. See, e.g., Ex. 1006 (Duan), Figs. 2, 3, 6, and 7. Even if
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`accommodation chamber 21 was spatially separated from cap 3 and connected to it
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`by tubing, accommodation chamber 21 (the alleged “pump chamber”) would
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`function independently of the alleged “thermal exchange chamber” formed by cap 3
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`and plate 1. See modified Figure 8 of Duan (shown below). Therefore, Duan does
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`not have a single receptacle, rather it has two receptacles that are attached together
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`to form cooling plate module 1.
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`Ex. 1006, Fig. 8 (modified to show spatial separation and with added annotations)
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`Even when Duan’s accommodation chamber 21 is rotated in view of Duan-I,
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`the cooling plate module 10 continues to have two receptacles, instead of one. The
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`Petition simply draws an orange outline around the rotated Duan device to assert that
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`accommodation chamber 21, cap 3, and cooling plate 1 together form a “reservoir.”
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`Pet. at 37. But the single-receptacle “reservoir” limitation cannot be satisfied by
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`attaching two receptacles, irrespective of their orientation.
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`Because Duan does not disclose, teach, or suggest a single-receptacle
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`“reservoir,” independent claims 1, 10, and 15, and the claims that depend therefrom,
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`are not rendered obvious by Duan alone (Ground 1) or by Duan in combination with
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`Duan-I (Ground 2).
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`IV. The Board Should Deny Institution of Ground 5 Under 35 U.S.C. § 325(d)
`The Board has discretion to deny review when “the same or substantially the
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`same prior art or arguments previously were presented to the Office.” 35 U.S.C.
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`§ 325(d). Specifically, § 325(d) provides that the Director may elect not to institute
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`trial if the challenge to the patent is based on matters previously presented to the
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`Office. Advanced Bionics, LLC v. MED-EL Elektromedizinische Geräte GmbH,
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`IPR2019-01469, Paper 6, 7-9 (P.T.A.B. Feb. 13, 2020) (precedential) (“Advanced
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`Bionics”). When evaluating matters under § 325(d), the Board uses the following
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`two-part framework outlined in Advanced Bionics: (1) determining whether the same
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`or substantially the same art previously was presented to the Office, or whether the
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`same or substantially the same arguments previously were presented to the Office;
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`and (2) if either condition of the first part of the framework is satisfied, determining
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`whether the petitioner has demonstrated that the Office erred in a manner material
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`to the patentability of the challenged claims. Id. at 8.
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`In applying this two-part framework, the Board considers the following non-
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`exclusive factors:
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`(a) the similarities and material differences between the asserted art and the
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`prior art involved during examination;
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`(b) the cumulative nature of the asserted art and the prior art evaluated during
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`examination;
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`(c) the extent to which the asserted art was evaluated during examination,
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`including whether the prior art was the basis for rejection;
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`(d) the extent of the overlap between the arguments made during examination
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`and the manner in which Petitioner relies on the prior art or Patent Owner
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`distinguishes the prior art;
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`(e) whether Petitioner has pointed out sufficiently how the Examiner erred in
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`its evaluation of the asserted prior art; and
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`(f) the extent to which additional evidence and facts presented in the Petition
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`warrant reconsideration of the prior art or arguments.
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`Becton, Dickinson & Co. v. B. Braun Melsungen AG, IPR2017-01586, Paper 8, 17-
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`18 (P.T.A.B. Dec. 15, 2017) (precedential as to § III.C.5, first paragraph). If, after
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`review of factors (a), (b), and (d), the Board determines that the same or substantially
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`the same art or arguments were previously presented to the Office, then factors (c),
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`(e), and (f), which relate to whether the petitioner demonstrates that the Office erred
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`in a manner material to the patentability of the challenged claims, is considered in
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`determining whether trial should be instituted. Advanced Bionics at 10.
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`Here, the Board should exercise its discretion under §325(d) to deny
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`institution based on Ground 5 (Batchelder in view of Duan) because the Examiner
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`previously considered the Batchelder reference and used it as a basis for rejection in
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`an Office Action, and Petitioner failed to demonstrate any material error of the
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`Examiner that warrants reconsideration.
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`A.
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`Part One of The Advanced Bionics Framework
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`1.
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`Becton, Dickinson Factors (a) and (b): The Prior Art Cited
`by Petitioner is the Same Prior Art Considered by the
`Examiner.
`The primary reference of Ground 5, Batchelder, was previously considered
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`by the Examiner during prosecution of the ’764 patent and applied as a basis for
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`prior-art rejection. See Ex. 1004, PDF pp. 101-105 (showing rejection of claims
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`based on Tamioka (U.S. Patent Pub. No. 2005/0069432) in combination with
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`Batchelder). Patent Owner successfully argued that Tamioka does not disclose a
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`reservoir having a “thermal exchange chamber” separate from the “pump chamber”
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`and vertically spaced apart from it, and that Batchelder does not overcome
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`Tamioka’s deficiencies. Id. at PDF pp. 79-86. The claims were subsequently allowed
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`over Batchelder. Id. at PDF pp. 58-59. Accordingly, it is evident that the Examiner
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`substantively considered Batchelder and found that it does not meet the limitations
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`of independent claims 1, 10, and 15. Petitioner fails to acknowledge that Batchelder
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`was considered during prosecution, much less explain any errors in the Examiner’s
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`evaluation.
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`2.
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`Becton, Dickinson Factor (d): Substantially the Same
`Arguments Were Previously Considered by The Examiner.
`The Examiner agreed with Patent Owner during prosecution of the ’764
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`patent that Batchelder does not disclose a “thermal exchange chamber” separate
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`from the “pump chamber” and vertically spaced apart from it. Ex. 1004 at PDF p.
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`59. Yet, Petitioner’s arguments regarding Batchelder are substantially the same
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`as those considered by the Examiner. See Pet. at 95-103, 124-129, 132-135. That
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`is, Petitioner applied Batchelder in the same way as rejected by the Examiner.
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`B.
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`Part Two of the Advanced Bionics Framework
`Becton, Dickinson Factor (c): Batchelder Was Substantially
`1.
`Evaluated During Examination.
`Batchelder was not only considered, but was the basis of a prior-art rejection
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`during prosecution. See Section IV.A.1, supra. Thus, Batchelder was substantially
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`evaluated during prosecution and the claims were allowed over Batchelder.
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`2.
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`Becton, Dickinson Factors (e) and (f): Petitioner Failed
`to Sufficiently Point Out How the Examiner Erred or
`Why the Evidence and Facts of the Petition Warrant
`Reconsideration.
`Petitioner failed to provide any indication that the Examiner erred in his
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`prior art analysis during the prosecution of the ’764 patent, including the reasons for
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`allowance in the Notice of Allowance. See Ex. 1004, PDF pp. 58-59. For example,
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`Petitioner failed to identify any specific teaching in the Batchelder reference
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`that the Examiner misapprehended or overlooked. Nor did Petitioner provide
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`any additional evidence or facts that warrant reconsideration of the Examiner’s
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`determination. In particular, Petitioner has not explained why the Examiner is
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`incorrect in his finding that Batchelder does not disclose a “thermal exchange
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`chamber” separate from the “pump chamber” and vertically spaced apart from it,
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`which is required by each of the independent claims 1, 10, and 15:1
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`Ex. 1004, PDF p. 59. Nor has Petitioner explained how Duan overcomes
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`Batchelder’s deficiency with respect to the Examiner’s above findings.
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`Because Petitioner has not sufficiently demonstrated how the Examiner
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`erred in his evaluation of Batchelder in a manner material to patentability of the
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`challenged claims, part two of the Advanced Bionics framework supports denial of
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`institution based on Ground 5 (Batchelder in view of Duan). See Advanced Bionics
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`at 8.
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`1 Claim 1, 12, and 17 during prosecution issued as independent claims 1, 10, and
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`15.
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`14
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`V. Conclusion
`Institution based on Grounds 1 and 2 should be denied because Duan fails to
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`disclose a single-receptacle “reservoir.” And institution based on Ground 5 should
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`be denied under 35 U.S.C. § 325(d) because Batchelder was fully considered during
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`prosecution. The remaining grounds (Grounds 3, 4, and 6) pertain only to dependent
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`claims and do not overcome the deficiencies of Grounds 1, 2, and 5. For the above
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`reasons, Petitioner fails to meet its burden of showing why inter partes review
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`should be instituted. The Board should accordingly deny institution of inter partes
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`review.
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`Dated: November 8, 2022
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`Respectfully submitted,
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`By: /Arpita Bhattacharyya/
` Arpita Bhattacharyya
`Reg. No. 63,681
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`CERTIFICATE OF COMPLIANCE
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`Pursuant to 37 C.F.R. § 42.24(d), I, Arpita Bhattacharyya, certify that
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`PATENT OWNER’S PRELIMINARY RESPONSE contains 2,715 words,
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`excluding those portions identified in 37 C.F.R. § 42.24(a), as measured by the word-
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`processing system used to prepare this paper.
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`Dated: November 8, 2022
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`By: /Arpita Bhattacharyya/
` Arpita Bhattacharyya
` Reg. No. 63,681
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I, William Esper, certify that on November
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`8, 2022, a copy of PATENT OWNER’S PRELIMINARY RESPONSE and
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`EXHIBITS 2001 – 2003 were served upon the below-listed counsel by electronic
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`mail:
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`James L. Ryerson
`Greenberg Traurig, LLP
`500 Campus Drive, Suite 400
`Florham Park, NJ 07932
`RyersonJ@gtlaw.com
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`Heath J. Briggs
`Greenberg Traurig, LLP
`1144 15th St., Suite 3300
`Denver, CO 80202
`BriggsH@gtlaw.com
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`Kyle D. Chen
`Greenberg Traurig, LLP
`1900 University Avenue, 5th Floor
`East Palo Alto, CA 94303
`kchen@gtlaw.com
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` By: /William Esper/
` William Esper
` Case Manager
` FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
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`Dated: November 8, 2022
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