Obviousness

Obviousness Analysis under 35 U.S.C. § 103 for US Patent 8610397

This analysis assesses the obviousness of US Patent 8610397 ("the '397 patent") based on the prior art explicitly discussed within its own text. The prior art date for the '397 patent is February 11, 2004. The '397 patent identifies a problem with existing battery chargers, including those described in U.S. Pat. No. 6,184,652 to Yang ('652 Yang) and U.S. Pat. No. 6,362,610 to Yang ('610 Yang), stating that "problems may still arise when different types of batteries are interchanged in different portable devices" and that "using chargers such as those described above where the battery and device charging parameters are not carefully matched could result in damage to the device and/or battery." [Description] This statement itself provides a clear motivation for a person having ordinary skill in the art (PHOSITA) to combine and modify the teachings of these prior art references.

Independent Claims Overview (Recap):

The independent claims of the '397 patent (Claims 1, 11, and 18) generally describe a battery charger, system, or method for charging a portable wireless communications device with a rechargeable battery. Key elements include:

• The portable device and rechargeable battery each have a type with respective charging rates.
• A controller is configured to cause the portable device to identify its corresponding portable device type and its corresponding rechargeable battery type.
• The charging circuit then charges the battery based on these identified types and their respective charging rates.

Prior Art References:

1. U.S. Pat. No. 6,184,652 to Yang ('652 Yang):

   • Discloses a mobile phone battery charger with a USB interface. [Description]
   • Includes a USB compatible plug, a DC converter, and a mobile phone battery charging plug. [Description]
   • The charger "may also detect the type of mobile phone battery (e.g., Li or Ni-MH) and the quantity of electricity or charge stored in the battery." [Description]
   • Aims to eliminate the need for users to purchase different chargers for different battery types. [Description]

2. U.S. Pat. No. 6,362,610 to Yang ('610 Yang):

   • Discloses a universal USB power supply unit. [Description]
   • Includes a USB port connector and a charging connector for an electronic product. [Description]
   • Features an automatic voltage regulator with a DC voltage transformer to convert USB voltage (e.g., 5V) to the "requisite voltage." [Description]
   • A "voltage parameter associated with the particular electronic device is preset within the charging connector using a variable resistor." [Description]

Obviousness Combination and Motivation: '652 Yang in view of '610 Yang

A PHOSITA, at the time of the '397 patent's priority date (February 11, 2004), would have been aware of the universal USB charging solutions exemplified by the Yang patents. The '397 patent itself identifies a deficiency in these existing solutions: they do not adequately account for situations where the charging parameters of the portable device and its battery are mismatched, potentially leading to damage. [Description] This recognition of a known problem in the field provides a strong motivation for a PHOSITA to combine and improve upon the existing art.

Motivation to Combine:

The '652 Yang patent teaches a USB charger that can detect different battery types (e.g., Li or Ni-MH) and adjust charging based on that detection. [Description] The '610 Yang patent teaches a universal USB power supply that acknowledges device-specific voltage requirements by allowing a voltage parameter to be preset within the charging connector using a variable resistor. [Description]

A PHOSITA aiming to address the problem of potential damage from mismatched device and battery charging parameters, as identified by the '397 patent, would find it obvious to combine these teachings. The goal would be to create a more truly "universal" and safe charger capable of intelligently adapting to both the device's limitations and the battery's limitations.

How the Combination Renders the Claims Obvious:

1. Portable wireless communications device with rechargeable battery and types: Both Yang patents address charging portable electronic devices, including mobile phones (which are portable wireless communication devices) with rechargeable batteries. The concept of device and battery "types" with "respective charging rates" is implicitly or explicitly taught by the identification/detection features in both references.

2. Charging circuit and controller: Both prior art references describe or imply the presence of a charging circuit and a controller to manage the charging process, as is standard in battery chargers.

3. Controller configured to cause the portable device to identify its corresponding portable device type and its corresponding rechargeable battery type:

   • '652 Yang teaches the charger can "detect the type of mobile phone battery." [Description] This directly covers identifying the "rechargeable battery type."
   • '610 Yang discloses that a "voltage parameter associated with the particular electronic device is preset within the charging connector." [Description] While this is a static, preset method, a PHOSITA seeking a more dynamic and robust solution (especially given the problem of mismatched parameters) would recognize that portable devices communicating their specific parameters via the existing USB data lines (as already used for enumeration) would be a superior and obvious extension. The '397 patent itself describes using "otherwise invalid USB enumeration states" to prompt the device to "enter a charging mode" and communicate its parameters. [Description] Given the known communication capabilities of USB devices, making the device actively "identify" and communicate its parameters, rather than relying on a static preset, would be an obvious design choice for improved universality and safety.

4. Cause the charging circuit to charge the rechargeable battery based on the respective charging rate thereof:

   • '652 Yang adjusts charging based on the detected battery type ("converts the electrical power into the necessary charging voltage"). [Description]
   • '610 Yang supplies the "requisite voltage" based on the preset device parameter. [Description]
   • Once a PHOSITA combines the teachings to identify both the battery type (from '652 Yang) and the device type/parameters (by dynamically modifying the '610 Yang approach to communicate rather than preset), it would be a straightforward engineering decision to compare these parameters. The '397 patent's core solution of selecting "one or more actual charging parameters... based upon a comparison of the different portable device and battery charging parameters to avoid damaging one or the other" by selecting a "limiting one" [Description] is a direct and obvious response to the identified problem of mismatched parameters in existing universal chargers. If a device has a lower voltage tolerance than a battery, or vice-versa, selecting the lower (limiting) value for charging is a fundamental safety measure that a PHOSITA would readily implement.

Conclusion:

The '397 patent explicitly states the shortcomings of the existing universal USB chargers, specifically those by Yang, regarding the potential for damage due to mismatched device and battery charging parameters. This clearly articulates a problem known in the art. Combining the battery type detection of '652 Yang with the device-specific parameter consideration of '610 Yang, and further enabling dynamic communication from the device for its parameters (an obvious modification given USB's communication capabilities and the stated problem), would be well within the capabilities of a PHOSITA. The subsequent step of comparing these identified parameters and selecting the most limiting ones for safe charging is a logical and obvious engineering solution to the known problem. Therefore, the independent claims of US8610397 would have been obvious in light of the combination of U.S. Pat. No. 6,184,652 to Yang and U.S. Pat. No. 6,362,610 to Yang, with the clear motivation provided by the '397 patent's own background section.