IP Law Daily, PATENT—Fed. Cir.: PTAB’s invalidation of licensing entity’s wireless charging patent upheld on appeal, (Oct 24, 2025)

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

PTAB correctly construed key claim terms and found sufficient motivation to combine prior art.

In a non-precedential disposition, the U.S. Court of Appeals for the Federal Circuit affirmed the Patent Trial and Appeal Board’s (PTAB) ruling that all challenged claims of a wireless power transfer patent owned by Nera Innovations Limited were unpatentable. The appellate court held that the Board correctly construed the claim term "coupled" and properly found a sufficient motivation to combine cited prior art references (Nera Innovations Ltd. v. Squires, No. 24-1079 (Fed. Cir. Oct. 24, 2025)).

Background. The appellant, Nera Innovations Limited, is a patent holding and licensing entity that acquired the asserted U.S. Patent No. 7,825,537 (the ’537 patent) from Scramoge Technology Limited. The ’537 patent concerns wireless charging technology and discloses a system for transferring power from a base unit to a target device using inductive coupling between coils. The inter partes review challenging the validity of the ’537 patent had been initiated by Apple Inc. The U.S. Patent and Trademark Office (USPTO) intervened in the appeal through its Director.

Apple’s IPR petition challenged claims 1–22 and 28 of the ’537 patent on grounds of anticipation and obviousness based on several prior art references. The PTAB found all challenged claims unpatentable in its final written decision. On appeal, Nera limited its challenge to the Board’s findings that dependent claims 16 and 19–22 were obvious in light of U.S. Patent No. 7,211,986 (Flowerdew) and U.S. Patent App. Pub. No. 2004/0218406 (Jang). Nera argued that the Board misconstrued the claim term "coupled" and failed to justify combining these references adequately.

Claim construction. Nera contended that the PTAB erred in construing the term "coupled" in claim 15 as encompassing electrical and non-electrical (magnetic or inductive) connections, arguing that it should be limited to electrical coupling. The Federal Circuit disagreed, affirming the Board's broader interpretation. Citing Phillips v. AWH Corp., 415 F.3d 1303, 1314–15 (Fed. Cir. 2005) (en banc), the court emphasized that claim differentiation strongly supported the Board’s view: while claim 15 used the general term “coupled,” claims 23 and 27 explicitly used “electrically coupled.” This variance indicated that the patentee deliberately chose not to limit claim 15 to electrical coupling.

The court also rejected Nera’s argument that the specification restricted “coupled” to electrical connections, citing Hill-Rom Services, Inc. v. Stryker Corp., 755 F.3d 1367, 1371 (Fed. Cir. 2014), which prohibits importing limitations from embodiments into claims. It reasoned that while the specification may have described electrical coupling, nothing in the claim language mandated such a restriction. The Federal Circuit concluded that Flowerdew’s teaching of a “sense coil” interface—inductively coupled to the primary coil—met the “coupled” limitation.

Obviousness. Nera further argued that the PTAB failed to articulate a sufficient rationale for combining the Flowerdew and Jang references. The Federal Circuit, applying the substantial evidence standard of review under Intel Corp. v. PACT XPP Schweiz AG, 61 F.4th 1373, 1378 (Fed. Cir. 2023), found ample support for the Board’s conclusion. The PTAB had determined that Flowerdew’s oscillator design was simplified and that the reference explicitly allowed for alternative implementations. Incorporating Jang’s inverter would have supplied practical implementation details to realize Flowerdew’s digital driver circuit.

The appellate court found that substantial evidence supported the Board’s conclusion that a skilled artisan would have been motivated to use Jang’s inverter within Flowerdew’s charging system to improve control and efficiency. Finding no reversible error, the Federal Circuit fully affirmed the PTAB's decision.

The Case is No. 24-1079.

Judge: Prost, S.

Attorneys: Robert Auchter (Auchter PLLC) for Nera Innovations Ltd. Robert McBride, U.S. Patent and Trademark Office, for John A. Squires.

Companies: Nera Innovations Ltd.; Apple Inc.

Cases: Patent FedCirNews USPTO