IP Law Daily, PATENT—Fed. Cir.: Patent licensing entity’s power converter patents properly succumbed to Samsung’s challenge, (Apr 25, 2025)

By Saurabh Kashyap, B.A., LL.B., LL.M.

PTAB correctly found the challenged claims anticipated and obvious in view of prior art and applied appropriate claim constructions.

The U.S. Court of Appeals for the Federal Circuit affirmed two final written decisions of the Patent Trial and Appeal Board (PTAB), invalidating all claims of two power converter patents owned by MyPAQ Holdings Ltd. The Board's decisions arose from inter partes reviews (IPRs) instituted on petitions by Samsung Electronics Co., Ltd. and joined by Dell Technologies Inc. and Anker Innovations Ltd. The Federal Circuit held that the Board correctly construed key disputed terms and that substantial evidence supported its anticipation and obviousness findings based on two prior art references (MyPAQ Holdings Ltd. v. Samsung Electronics Co., Ltd., Nos. 23-2024, 23-2025 (Fed. Cir. Apr. 24, 2025)).

Background. The appellant, MyPAQ Holdings Ltd., owns U.S. Patent Nos. 8,477,514 (the ’514 patent) and 7,675,759 (the ’759 patent), both directed to power converters that dynamically regulate output voltage based on system state and load requirements. The patents disclose controllers for switch-mode power supplies that adapt duty cycles and switching frequencies in response to processor activity levels or other system signals.

Samsung Electronics, along with Dell and Anker, filed IPR petitions challenging the validity of all claims in both patents. Samsung contended that the claims were anticipated and/or rendered obvious by U.S. Patent Nos. 6,873,136 (Chagny) and 6,294,904 (Hirst), both of which disclose adaptive switching regulators for processor power management.

The ’514 and ’759 patents share substantially similar specifications and claim switch-mode power converters that regulate output by dynamically adjusting switching frequency and duty cycle based on signals indicative of processor state. One asserted improvement over prior art lies in the use of a controller that monitors the "core state" and other internal processor states to optimize power efficiency. According to the patents, “core state” refers to processor operating levels that influence power consumption, and the claimed systems seek to respond to such states at startup or during continued operation.

The PTAB held that all challenged claims of the ’514 patent were anticipated or obvious over Chagny, while the claims of the ’759 patent were anticipated or obvious based on Chagny and, in some cases, Hirst. MyPAQ appealed, contesting the Board's claim constructions and factual findings.

Claim construction of “core state.” The most prominent dispute on appeal concerned the meaning of “core state.” MyPAQ contended that the term should be limited to “C-states” defined in the ACPI (Advanced Configuration and Power Interface) specification, such as C0 through C4 processor sleep states. It argued that the patent acted as its own lexicographer by using the term “core state (‘C-state’)” and referencing the ACPI standard.

The Federal Circuit disagreed, affirming the Board’s broader construction of “core state” as encompassing processor activity levels beyond ACPI C-states. The panel explained that references to ACPI C-states in the specification were illustrative rather than definitional. Citing Thorner v. Sony Comput. Ent. Am. LLC, 669 F.3d 1362 (Fed. Cir. 2012), the court noted that lexicography requires a clear and deliberate intent to redefine a term. Here, no such redefinition was found. Instead, the patents described ACPI states as "examples" of core states and used the unmodified term "core state" elsewhere without reference to ACPI. The court concluded that the Board correctly construed the term as including processor activity levels, such as instruction execution rate, consistent with Samsung's interpretation.

Disclosure of “core state” in prior art. Applying the Board’s construction, the Federal Circuit found that substantial evidence supported the Board’s conclusion that Chagny disclosed the “core state” limitation. Chagny’s system used a controller module to receive processor activity inputs and adjust the switching frequency accordingly. The court cited Bot M8 LLC v. Sony Interactive Ent. LLC, 66 F.4th 1380 (Fed. Cir. 2023), to reaffirm that motivation to combine and the content of prior art are factual inquiries reviewed for substantial evidence. Because MyPAQ did not dispute the Board's factual finding that Chagny disclosed the 'core state' limitation under the adopted construction, the court affirmed the Board's unpatentability determination for the claims containing that limitation.

Construction and application of “upon startup.” MyPAQ also disputed the Board's implicit construction of "upon startup," asserting that the term should be limited to signals generated strictly during the processor's boot sequence and not during continued operation. The Federal Circuit rejected this argument, holding that nothing in the specification mandated such a rigid interpretation. The court found that Chagny’s periodic updating of activity input signals beginning at power-up satisfied the “upon startup” requirement. It upheld the Board’s finding that this limitation was met and that claims 13 and 18 of the ’514 patent were obvious over Chagny.

Meaning of “processor system.” The court similarly upheld the Board’s understanding of “processor system” as including individual processors with multiple internal components. MyPAQ had argued that a processor system must refer to a broader computing system such as a server or PC. However, the Federal Circuit noted that the specification described processor systems as "often" comprising multiple components, not necessarily doing so. Citing Chagny’s use of a processor with internal modules, the court found substantial evidence that the prior art satisfied the limitation.

Power system controller and duty cycle. Further, MyPAQ challenged the Board’s finding that Chagny disclosed a “power system controller” capable of system-wide coordination. It argued that the cited software program in Chagny merely monitored activity rather than exercising control. The court disagreed, affirming the Board’s determination that Chagny’s controller exerted power control by adjusting the switching frequency in response to processor activity inputs.

MyPAQ also argued that Chagny did not disclose a “duty cycle” because it did not use the term or discuss periodicity. But the court upheld the Board’s application of the agreed construction—“the ratio represented by a conduction period of a power switch to a switching period thereof.” It found that Chagny’s description of chopping the DC voltage input using a power switch at a selected switching frequency inherently disclosed a duty cycle. The court cited testimony from Samsung’s expert explaining that turning a switch on and off at a frequency necessarily creates a duty cycle, satisfying the limitation.

Remaining arguments and disposition. MyPAQ did not appeal the Board’s findings that certain claims of the ’759 patent were unpatentable under Hirst, rendering several of its arguments moot. The court noted that even if MyPAQ had prevailed on its disputed constructions, key claims would remain unpatentable based on alternative grounds not challenged in the appeal.

Having found no reversible error in the Board’s constructions or factual findings, the Federal Circuit affirmed the invalidation of all challenged claims.

The Case is Nos. 2023-2024, 2023-2025.

Judge: Stark, L.

Attorneys: James Carmichael (Carmichael LP) for MyPaq Holdings Ltd. Eliot Damon Williams (Baker Botts LLP) for Samsung Electronics Co., Ltd., Dell Technologies Inc., and Anker Innovations Ltd.

Companies: MyPaq Holdings Ltd.; Samsung Electronics Co., Ltd.; Dell Technologies Inc.; Anker Innovations Ltd.

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