Power-One, Inc. v. Artesyn Technologies, Inc.

Citations: 599 F.3d 1343; 94 U.S.P.Q. 2d (BNA) 1241; 2010 U.S. App. LEXIS 6487; 2010 WL 1192309Docket: 08-1501

Court: Court of Appeals for the Federal Circuit; March 30, 2010; Federal Appellate Court

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Power-One, Inc. sued Artesyn Technologies, Inc. for infringing its U.S. Patents Nos. 7,000,125, 6,936,999, 6,949,916, and 7,049,798, which pertain to power supply systems that manage point-of-load (POL) regulators. Following a jury trial, the United States District Court for the Eastern District of Texas, under Magistrate Judge John D. Love, issued a permanent injunction against Artesyn based on the jury's findings that Artesyn directly infringed specific claims of the ’125 patent and did not successfully prove its invalidity. Artesyn appealed, arguing that the district court's claim construction of "POL regulator" was insufficient and that it erred in denying its motion for judgment as a matter of law regarding the patent's obviousness. The Federal Circuit, comprising Chief Judge Michel, Circuit Judge Gajarsa, and District Judge Kendall, affirmed the district court's decision, finding no errors in the issues raised on appeal. The background includes a description of how Power-One’s systems operate, emphasizing the role of regulators and the communication methods used in distributed power systems, namely serial and parallel buses, which connect multiple regulators to a system controller for data management. Independent claims 1 and 16 of the ’125 patent describe a power control system that integrates multiple POL regulators with a serial data bus linked to a system controller, facilitating the transmission of programming, control, and monitoring information.

Independent claim 16 describes a method for controlling multiple point-of-load (POL) regulators, involving the reception of programming parameters, serial transmission of digital programming data via a common data bus to the POL regulators, and the reception of performance monitoring data from those regulators. Independent claim 23 pertains to a POL regulator, which consists of a power conversion circuit, a controller, and a serial bus interface for programming and monitoring communications. Specifically, it includes a power conversion circuit that converts an intermediate voltage to an output voltage, a serial data bus interface for data communication, and a controller that adjusts the power conversion circuit's operating parameters based on programming information and generates monitoring information based on the circuit's operational characteristics.

The term "POL regulator" was not defined in the relevant patent but was construed by the district court following a Markman hearing as a dc/dc switching voltage regulator designed to receive power from a voltage bus on a printed circuit board, supplying power to specific devices on the board in a distributed power system. After a jury found Artesyn to have directly infringed multiple claims of the patent and failed to establish invalidity claims, Artesyn's motion for judgment as a matter of law regarding invalidity and non-infringement was denied, resulting in a permanent injunction and an amended final judgment, which Artesyn has appealed.

On appeal, Artesyn raises two key issues: the adequacy of the district court’s construction of the term "POL regulator," arguing it was not sufficiently precise or that the term is indefinite, and challenges the jury’s finding of validity, asserting the patent is obvious as a matter of law. The court will review the claim construction de novo, with intrinsic evidence being the primary resource for interpretation, and terms will be given their ordinary meaning as understood by a person skilled in the art at the time of the invention, ensuring clarity for the jury regarding what the claims encompass.

Artesyn argues that the district court's definition of the claim term "POL regulator" is flawed, lacking precision regarding the scope of the asserted claims of the ’125 patent. Specifically, Artesyn claims that the terms "adapted" and "near" are vague and subjective, allowing the jury to determine the scope contrary to the Markman standard. The district court, however, defined "POL regulator" as a DC/DC switching voltage regulator that receives power from a voltage bus on a printed circuit board and is designed to power devices on the board while being positioned near those devices within a distributed board-level power system. The court's construction is supported by the intrinsic record, demonstrating that the terms "adapted to" and "near" are not ambiguous. According to precedent, terms are only considered ambiguous if they provide no guidance to skilled individuals in the field. A skilled artisan would understand the meanings of "near" and "adapted to," as the context provides necessary precision. The construction implies that the POL regulator is meant to be placed close to the load it powers, as indicated by the patent specification, which states that the POL regulator should be positioned just upstream from the load and ideally adjacent to the corresponding circuit to minimize the length of low voltage, high current lines. This specification clarifies the appropriate placement of the regulator relative to the load, ensuring functionality and efficiency in power delivery.

The term 'POL regulator' is defined as a device that delivers power at the necessary intensity to one or more loads on a circuit board, as specified in the ’125 patent. The patent indicates that each electronic circuit includes a POL regulator to convert bus voltage to the required level, making it clear to skilled artisans that the output power aligns with the needs of the circuit. The lack of precise numerical measurements does not hinder the term's guidance, as the overall context of the patent sufficiently informs a skilled artisan about its meaning. 

In addressing the definiteness of 'POL regulator,' the district court's determination that the term is not indefinite is upheld. Under 35 U.S.C. § 112, claims must distinctly point out the subject matter of the invention. The boundaries of the claim must be clear to a skilled artisan based on the claim language, specification, and prosecution history. A claim is deemed indefinite only if it is not amenable to construction or is insolubly ambiguous. However, mere difficulty in construction does not equate to indefiniteness. The intrinsic evidence of the ’125 patent indicates that POL regulators are recognized devices within the field, and their placement and function are well understood. Therefore, the term 'POL regulator' is deemed definite, affirming the validity of the claims in the patent.

Artesyn contests the district court's denial of its motion for judgment as a matter of law (JMOL) regarding the validity of the ’125 patent, arguing that the patent's power system would have been obvious to a person of ordinary skill in the art. The review of such a denial follows the procedural law of the regional circuit, in this case, the Fifth Circuit, which evaluates JMOL motions de novo and upholds jury verdicts unless there is insufficient evidence for a reasonable jury to rule in favor of the nonmovant. Under 35 U.S.C. § 103, a patent cannot be issued if its differences from prior art would have been obvious at the time of the invention. The determination of obviousness involves both legal and factual analyses, including the scope of prior art, differences from the claimed invention, the skill level of the art, and secondary considerations such as commercial success and the failure of others. To succeed in its JMOL, Artesyn needed to provide clear and convincing evidence of obviousness. At trial, Artesyn presented seven pieces of prior art and relied on expert testimony, which conflicted with that of Power-One's expert. The jury was entitled to discredit Artesyn’s expert's claims about the broad scope of prior art and minor differences, while favoring Power-One's expert, who highlighted significant distinctions that rendered the invention non-obvious.

Ehsani's expert opinion stated that no prior art references demonstrated the use of a serial data bus for bidirectional communication between a system controller and multiple POL regulators, particularly for control, programming, and monitoring information. The jury favored Power-One’s expert testimony over Artesyn’s claims that the '125 patent was obvious based on prior art elements. The district court highlighted that having known elements does not automatically render a patent obvious, as established in KSR, 550 U.S. at 418. Stewart's testimony lacked a credible explanation for how the cited prior art could combine to invalidate the '125 patent. Power-One also presented evidence of secondary considerations, such as industry praise, which supported the jury's conclusion against the patent's invalidity. Artesyn's launch of its own product, the DPL20C, which claimed advancements over previous options, contradicted its assertion that Power-One's invention was obvious. Furthermore, industry recognition and praise for Power-One’s patented features, especially from competitors, indicated nonobviousness. Evidence suggested that Artesyn copied Power-One's invention, which is a relevant factor in assessing obviousness. Overall, the evidence supported the conclusion that significant differences existed between the '125 patent and the prior art, affirming the district court’s decision against Artesyn's motion for judgment as a matter of law (JMOL) on validity.