US 8610397

US Patent 8610397: Smart Battery Charger for Portable Wireless Devices

Title: Battery charger for portable devices and related methods
Current Assignee: Malikie Innovations Ltd
Inventors: Michael L. Purdy, Ryan Mitchell Bayne
Filing Date: January 24, 2012
Issue Date: December 17, 2013
Abstract: A battery charger for portable devices and methods that intelligently adapts its charging parameters. The charger includes a connector, a charging circuit, and a controller. This controller determines the specific type of portable device and its rechargeable battery, then adjusts the charging process based on their respective charging requirements.

Independent Claims Overview:

Claim 1 (Battery Charger Apparatus):
This claim describes a battery charger specifically designed for portable wireless communication devices. The portable wireless communication device has a rechargeable battery and a wireless communication transceiver. Both the device and the battery have specific "types" that determine their charging rates. The charger itself consists of a charging circuit and a controller. The controller is programmed to identify the specific type of the connected portable wireless communication device and its rechargeable battery. Based on this identification, the controller instructs the charging circuit to charge the battery according to its appropriate charging rate.

Claim 11 (Battery Charging System):
This claim defines a complete battery charging system. It includes a portable wireless communication device, which itself comprises a rechargeable battery and a wireless communication transceiver. Similar to Claim 1, both the device and the battery have designated types with corresponding charging rates. The system also incorporates the battery charger as described in Claim 1, which includes a charging circuit and a controller. The controller in this system is configured to identify the device and battery types and then direct the charging circuit to charge the battery based on their respective charging rates.

Claim 18 (Battery Charging Method):
This claim outlines a method for charging a rechargeable battery within a portable wireless communication device. The method acknowledges that the portable device and its battery each have a specific type with unique charging rates. The steps of the method involve connecting a charging circuit to the portable wireless communication device. This connection prompts the device to communicate its portable device type and rechargeable battery type. Subsequently, the charging circuit then proceeds to charge the rechargeable battery based on the identified charging rates.

Based on the provided patent text for US8610397B2, the following litigation is known:

• Case 1 (PTAB IPR)

  • Plaintiff(s): Petitioner is "Unified Patents PTAB Data".
  • Defendant(s): Not explicitly stated in the provided text, but typically the patent owner in an IPR.
  • Jurisdiction: Patent Trial and Appeal Board (PTAB).
  • Case Number: IPR2026-00006.
  • Filing Date: The Google Patents page indicates this case was filed in the future (IPR2026-00006). Assuming the filing date is 2026 for this case number.
  • Outcome or Current Status: Settlement.

• Case 2 (US District Court)

  • Plaintiff(s): Not explicitly stated in the provided text.
  • Defendant(s): Not explicitly stated in the provided text.
  • Jurisdiction: Washington Western District Court.
  • Case Number: 2:24-cv-01490.
  • Filing Date: Not explicitly stated, but the case number (2:24-cv-01490) suggests a 2024 filing year.
  • Outcome or Current Status: Litigation (current status is not further specified beyond "litigation").

• Case 3 (US District Court)

  • Plaintiff(s): Not explicitly stated in the provided text.
  • Defendant(s): Not explicitly stated in the provided text.
  • Jurisdiction: Texas Eastern District Court.
  • Case Number: 2:24-cv-00179.
  • Filing Date: Not explicitly stated, but the case number (2:24-cv-00179) suggests a 2024 filing year.
  • Outcome or Current Status: Litigation (current status is not further specified beyond "litigation").

• Case 4 (First Worldwide Family Litigation)

  • Plaintiff(s): Not explicitly stated in the provided text.
  • Defendant(s): Not explicitly stated in the provided text.
  • Jurisdiction: Worldwide (as it's "First worldwide family litigation"). Specific court not named.
  • Case Number: Not explicitly provided. The link leads to Darts-ip for family ID 34827378.
  • Filing Date: Not explicitly provided.
  • Outcome or Current Status: Litigation (current status is not further specified beyond "litigation").

Proceedings overview

There is one AIA trial proceeding on file for US Patent 8610397. This proceeding, IPR2026-00006, was terminated due to settlement, meaning no claims were formally invalidated or sustained by a Final Written Decision. As such, the patent claims remain untested by a PTAB final decision.

IPR2026-00006 — Nintendo Co., Ltd. et al. v. Malikie Innovations Ltd

• Type: Inter Partes Review
• Filed: 2025-10-08
• Status: Terminated-Settled. This indicates the parties reached an agreement and the proceeding was concluded without a Final Written Decision.
• Judge panel: Information regarding the specific judge panel for this IPR is not publicly available from the provided data or readily discoverable through general web searches for terminated/settled cases unless a formal institution decision or FWD was issued and made public.
• Petition grounds: Specific claims and prior art challenged in the petition are not publicly detailed for this terminated-settled IPR in the provided data or easily found via general web search without access to the full PTAB docket.
• Institution decision: Given the "Terminated-Settled" status and last modification date (2026-03-02), it is highly probable that the proceeding was settled before an institution decision was issued. The statutory deadline for an institution decision would typically be within six months of the filing date (April 8, 2026). The settlement occurred before this deadline.
• Final Written Decision (if issued): Not issued. The proceeding was terminated before reaching a Final Written Decision.
• Settlement / termination: The proceeding was terminated as "Terminated-Settled" on or before 2026-03-02. The specific terms of the settlement are generally confidential between the parties.
• Appeal: Not applicable, as no Final Written Decision was issued.
• Defensive value: This IPR's termination by settlement means that the patent's claims were not adjudicated by the PTAB. Therefore, a defendant facing assertion of this patent cannot rely on any invalidated claims from this proceeding. However, the settlement itself might indicate some strength in the petitioner's challenge or a strategic decision by the patent owner to avoid an FWD.

Strategic summary

All claims of US Patent 8610397 remain UNTESTED by a Final Written Decision from the PTAB. The single IPR filed, IPR2026-00006, was terminated as "Settled" before reaching a substantive ruling on patentability. This means that, from a defensive standpoint, there are no claims that have been formally canceled by the PTAB that a defendant can point to to immediately dismiss an infringement theory.

The estoppel landscape under § 315(e)(2) for this patent is currently limited. Since IPR2026-00006 was settled prior to institution (or at least prior to a final written decision), the petitioner (Nintendo Co., Ltd. et al.) and its privies would likely not be estopped from raising grounds that could have been raised in the IPR in future proceedings or litigation, provided a judgment on the merits was not reached. This is because estoppel typically applies to grounds "raised or reasonably could have been raised" in a trial that results in a final written decision. For other potential defendants, all prior-art grounds remain available to challenge the patent's validity, as no claims were confirmed patentable in a FWD.

The pattern signals indicate that at least one entity, Nintendo Co., Ltd. et al., initiated a challenge to this patent. However, the subsequent settlement suggests either a mutual agreement was reached, or the patent owner and petitioner resolved their dispute outside of the PTAB process. The fact that the proceeding settled before institution, or at least before a final decision, means the patent has not yet been "hardened" by surviving a PTAB trial.

Recommended next steps

For a defendant currently facing assertion of US Patent 8610397, the primary takeaway is that the claims are currently fully intact from a PTAB perspective.

• Review the claims carefully: Since no claims have been invalidated by the PTAB, a thorough independent analysis of all asserted claims of US8610397 against the prior art is critical.
• Investigate the IPR2026-00006 settlement: While the terms are confidential, understanding the context of the settlement (e.g., whether it was part of a broader litigation settlement) could provide strategic insights.
• Consider a new PTAB challenge: Given that the patent has not been subjected to a Final Written Decision, a new IPR could be a viable strategy if strong prior art exists. The lack of estoppel for other parties makes this an open avenue.
• Monitor for future PTAB activity: Keep an eye on the USPTO PTAB E2E portal for any new petitions against US8610397. The absence of further PTAB activity after the initial IPR settlement could be a signal, but a well-asserted patent will often attract multiple challenges.## Proceedings overview
  There is one AIA trial proceeding on file for US Patent 8610397. This proceeding, IPR2026-00006, was terminated due to settlement, meaning no claims were formally invalidated or sustained by a Final Written Decision. As such, the patent claims remain untested by a PTAB final decision, offering little specific defensive leverage from this particular proceeding for a defendant.

IPR2026-00006 — Nintendo Co., Ltd. et al. v. Malikie Innovations Ltd

• Type: Inter Partes Review
• Filed: 2025-10-08
• Status: Terminated-Settled. This indicates the parties reached an agreement and the proceeding was concluded without a Final Written Decision.
• Judge panel: Specific judge panel information for this IPR is not publicly available from the provided data or readily discoverable through general web searches for terminated/settled cases that did not reach an institution decision or Final Written Decision.
• Petition grounds: The specific claims challenged and the prior art relied upon in the petition are not publicly detailed for this terminated-settled IPR in the provided data or easily found via general web search without access to the full PTAB docket.
• Institution decision: Given the "Terminated-Settled" status with a last modified date of 2026-03-02, it is highly probable that the proceeding was settled before the six-month statutory deadline for an institution decision (which would have been approximately April 8, 2026) was reached. Therefore, no institution decision was issued.
• Final Written Decision (if issued): Not issued. The proceeding was terminated before reaching a Final Written Decision.
• Settlement / termination: The proceeding was terminated as "Terminated-Settled" on or before 2026-03-02. The specific terms of the settlement are generally confidential between the parties.
• Appeal: Not applicable, as no Final Written Decision was issued.
• Defensive value: This IPR's termination by settlement means that the patent's claims were not adjudicated by the PTAB. Therefore, a defendant cannot rely on any invalidated claims from this proceeding to counter an assertion. The settlement itself might indicate a strategic decision by the patent owner to avoid an FWD or a mutual agreement reached between the parties.

Strategic summary

All claims of US Patent 8610397 remain UNTESTED by a Final Written Decision from the PTAB. The single IPR filed, IPR2026-00006, was terminated as "Settled" before reaching a substantive ruling on patentability. This means that, from a defensive standpoint, there are no claims that have been formally canceled by the PTAB that a defendant can point to in order to immediately dismiss an infringement theory.

The estoppel landscape under § 315(e)(2) for this patent is currently limited. Since IPR2026-00006 was settled prior to an institution decision or a final written decision, the petitioner (Nintendo Co., Ltd. et al.) and its privies would generally not be estopped from raising grounds that could have been raised in the IPR in future proceedings or litigation, as estoppel typically applies only to grounds "raised or reasonably could have been raised" in a trial that results in a final written decision. For other potential defendants, all prior-art grounds remain available to challenge the patent's validity, as no claims were confirmed patentable in a FWD.

The pattern signals indicate that at least one entity, Nintendo Co., Ltd. et al., initiated a challenge to this patent. However, the subsequent settlement suggests either a mutual agreement was reached, or the patent owner and petitioner resolved their dispute outside of the PTAB process. The fact that the proceeding settled before institution, or at least before a final decision, means the patent has not yet been "hardened" by surviving a PTAB trial.

Recommended next steps

For a defendant currently facing assertion of US Patent 8610397, the primary takeaway is that the claims are currently fully intact from a PTAB perspective.

• Review the claims carefully: Since no claims have been invalidated by the PTAB, a thorough independent analysis of all asserted claims of US8610397 against relevant prior art is critical.
• Investigate the IPR2026-00006 settlement: While the terms are confidential, understanding the context of the settlement (e.g., whether it was part of a broader litigation settlement, or if it involved a license) could provide strategic insights into the patent owner's enforcement strategy and the perceived strength of the patent.
• Consider a new PTAB challenge: Given that the patent has not been subjected to a Final Written Decision, a new IPR could be a viable strategy if strong prior art exists. The lack of estoppel for other parties makes this an open avenue.
• Monitor for future PTAB activity: Keep an eye on the USPTO PTAB E2E portal for any new petitions filed against US8610397. The absence of further PTAB activity after the initial IPR settlement could be a signal regarding the patent's perceived strength or enforcement.

Inventors

• Michael L. Purdy: Employee of Research In Motion Limited (later BlackBerry Ltd) at the time of filing.
• Ryan Mitchell Bayne: Employee of Research In Motion Limited (later BlackBerry Ltd) at the time of filing.

Original assignee

BlackBerry Ltd (formerly Research In Motion Limited) was the original assignee named on the issued patent. At the time of filing and issuance, BlackBerry was a prominent manufacturer of smartphones, tablets, and communication software, actively shipping products embodying the claims related to portable devices and battery charging. Its primary line of business was mobile communications devices and services. BlackBerry Ltd is currently an operating company, having pivoted its business focus primarily to security software and services.

Assignment timeline

• 2012-01-19 (executed) / recorded 2012-01-24 — Reel 027415/0096

  • Conveyance: Assignment
  • Assignor: BAYNE, RYAN MITCHELL, PURDY, MICHAEL L.
  • Assignee: RESEARCH IN MOTION LIMITED
  • Correspondent: R. BARRY THOMPSON, Research In Motion Limited, 295 Phillip St, Waterloo, Ontario, N2L 3W8, CANADA.
  • Context: Initial assignment from the inventors to their employer.

• 2013-09-17 (executed) / recorded 2013-10-09 — Reel 031383/0942

  • Conveyance: Change of Name
  • Assignor: RESEARCH IN MOTION LIMITED
  • Assignee: BLACKBERRY LIMITED
  • Correspondent: R. BARRY THOMPSON, Blackberry Limited, 295 Phillip St, Waterloo, Ontario, N2L 3W8, CANADA. This correspondent also appeared on the prior assignment.
  • Context: Corporate name change of the original assignee.

• 2023-04-27 (executed) / recorded 2023-04-27 — Reel 063471/0474

  • Conveyance: Assignment of Assignor's Interest
  • Assignor: BLACKBERRY LIMITED
  • Assignee: OT PATENT ESCROW, LLC
  • Correspondent: OT PATENT ESCROW, LLC, 2734 N ASHLAND AVE #355, CHICAGO, IL, 60614.
  • Context: Transfer of patent from the original operating company (BlackBerry) to an escrow entity.

• 2023-06-12 (executed) / recorded 2023-06-16 — Reel 064015/0001

  • Conveyance: Nunc Pro Tunc Assignment
  • Assignor: OT PATENT ESCROW, LLC
  • Assignee: MALIKIE INNOVATIONS LIMITED
  • Correspondent: BRENT D. SHEAR, 10700 HARMON ROAD, #203, FORT WORTH, TX, 76140. This correspondent will recur in this chain.
  • Context: Transfer of patent from the escrow entity to a patent monetization firm, effective retroactively.

• 2023-06-15 (executed) / recorded 2023-06-19 — Reel 064065/0820

  • Conveyance: Nunc Pro Tunc Assignment
  • Assignor: BLACKBERRY LIMITED
  • Assignee: MALIKIE INNOVATIONS LIMITED
  • Correspondent: BRENT D. SHEAR, 10700 HARMON ROAD, #203, FORT WORTH, TX, 76140. This correspondent also appeared on the prior assignment.
  • Context: Direct transfer from BlackBerry to Malikie, likely clarifying or affirming the previous escrow transfer.

• 2023-08-30 (executed) / recorded 2023-09-05 — Reel 064438/0342

  • Conveyance: Corrective Assignment
  • Assignor: BLACKBERRY LIMITED
  • Assignee: OT PATENT ESCROW, LLC
  • Correspondent: BRENT D. SHEAR, 10700 HARMON ROAD, #203, FORT WORTH, TX, 76140. This correspondent also appeared on prior assignments.
  • Context: Corrective assignment related to the transfer between BlackBerry and the escrow entity.

• 2023-08-30 (executed) / recorded 2023-09-05 — Reel 064438/0347

  • Conveyance: Corrective Assignment
  • Assignor: OT PATENT ESCROW, LLC
  • Assignee: MALIKIE INNOVATIONS LIMITED
  • Correspondent: BRENT D. SHEAR, 10700 HARMON ROAD, #203, FORT WORTH, TX, 76140. This correspondent also appeared on prior assignments.
  • Context: Corrective assignment related to the transfer between the escrow entity and Malikie Innovations.

Timeline diagram

timeline
    title Ownership of US 8610397
    2012 : Filed by inventors
         : Assigned to Research In Motion Ltd
    2013 : Research In Motion becomes BlackBerry Ltd
    2023 : Assigned to OT Patent Escrow LLC
         : Assigned to Malikie Innovations Ltd
         : Corrective assignments recorded
    2024 : First infringement suits filed

NPE / troll-pattern signals

1. Shell-entity transfer — Present. The patent was transferred to "OT PATENT ESCROW, LLC" (Reel 063471/0474) and subsequently to "MALIKIE INNOVATIONS LIMITED" (Reel 064015/0001, 064065/0820). Both names suggest special-purpose entities for patent management, and their recorded addresses (suite numbers) can be indicative of registered agent services. Malikie Innovations Limited's self-description and extensive litigation history confirm a licensing and assertion focus rather than product sales.

2. Known asserter in the chain — Present. Malikie Innovations Limited is a known Non-Practicing Entity (NPE) and an entity of Key Patent Innovations Limited, explicitly identified by Unified Patents and RPX as a patent monetization firm that acquired BlackBerry's non-core patent portfolio to assert. Google Patents also lists multiple litigations involving Malikie Innovations Ltd, including PTAB cases and district court lawsuits.

3. Repeat correspondent across the chain — Present. Brent D. Shear (10700 HARMON ROAD, #203, FORT WORTH, TX, 76140) served as the correspondent of record for four assignments involving OT Patent Escrow, LLC and Malikie Innovations Limited (Reel 064015/0001, 064065/0820, 064438/0342, 064438/0347). This recurrence indicates a consistent legal representative for the patent assertion entities.

4. Cascading transfers — Present. Multiple assignments and corrective assignments occurred in quick succession from April to September 2023 (Reel 063471/0474, 064015/0001, 064065/0820, 064438/0342, 064438/0347), involving BlackBerry, an escrow entity, and Malikie Innovations Limited. This series of transfers within a few months is characteristic of cascading transfers.

5. Pre-litigation transfer — Unclear/Weak Signal. The primary transfers to Malikie Innovations Limited were executed and recorded in June 2023 (Reel 064015/0001, 064065/0820). The first infringement lawsuits related to this patent family were filed in March 2024 (e.g., 2:24-cv-00179), which is slightly outside the strict 6-month window. However, the acquisition of the BlackBerry portfolio by Key Patent Innovations (Malikie's parent) was completed in May 2023, and these transfers immediately preceded the subsequent widespread assertion campaign, indicating a strategic transfer for monetization purposes.

6. Bankruptcy fire-sale — Not present. BlackBerry Ltd is an active operating company, not in bankruptcy proceedings.

7. Privateering — Unclear. While BlackBerry sold its "non-core patents" to Malikie, suggesting a divestment strategy, there is no direct evidence to suggest that BlackBerry is actively directing Malikie's assertions against specific competitors.

8. Defensive aggregator (anti-NPE) — Not present. The current assignee, Malikie Innovations Limited, is an identified NPE.

Verdict

NPE — high confidence. The presence of multiple strong signals, including transfers to shell entities (OT Patent Escrow, LLC and Malikie Innovations Limited) (Reel 063471/0474, 064015/0001), the explicit identification of Malikie Innovations Limited as a known NPE by industry watchdogs (Unified Patents, RPX), and the recurrence of the same correspondent (Brent D. Shear) across multiple transfers to these entities (Reel 064015/0001, 064065/0820, 064438/0342, 064438/0347), collectively point to a high-confidence NPE assertion pattern. These transfers were also part of cascading assignments occurring within a short timeframe in 2023.

USPTO Assignment Center Search for US8610397

The USPTO database can be accessed through the Patent Public Search tool.

For US patent 8610397, the following prior art references are cited:

1. U.S. Pat. No. 6,184,652 to Yang

   • Full Citation: U.S. Pat. No. 6,184,652 to Yang.
   • Publication/Filing Date: Not explicitly stated in the provided text for 6,184,652, but US8610397B2 indicates it was prior art. The description of US8610397B2 states this patent "is directed to a mobile phone battery charger with a USB interface."
   • Brief Description: This patent describes a mobile phone battery charger with a USB interface. It includes a USB-compatible plug for receiving power from a computer, a DC converter to adjust the voltage, and a mobile phone battery charging plug. The charger can detect the battery type (e.g., Li or Ni-MH) and its charge level, aiming to eliminate the need for different chargers for different battery types.
   • Potential Anticipated Claims (35 U.S.C. § 102): This patent potentially anticipates elements of claims 1, 11, and 18 that relate to a battery charger with a connector (specifically USB), a charging circuit, and the ability to detect battery type for charging. However, 8610397 emphasizes identifying both portable device type and rechargeable battery type, and adjusting charging based on a comparison of their parameters to prevent damage, which 6,184,652 may not fully address. The text states 6,184,652 allows a user to "not purchase different kinds of chargers for different battery types."

2. U.S. Pat. No. 6,362,610 to Yang

   • Full Citation: U.S. Pat. No. 6,362,610 to Yang.
   • Publication/Filing Date: Not explicitly stated in the provided text for 6,362,610, but US8610397B2 indicates it was prior art.
   • Brief Description: This patent discloses a universal USB power supply unit. It features a USB port connector that plugs into a USB port and a charging connector for an electronic product. An automatic voltage regulator with a DC voltage transformer converts the USB voltage (e.g., 5V) to the required charging voltage. A feedback control voltage output circuit adjusts the output voltage to a preset level, and a voltage parameter for the specific electronic device is preset within the charging connector using a variable resistor.
   • Potential Anticipated Claims (35 U.S.C. § 102): Similar to U.S. Pat. No. 6,184,652, this patent potentially anticipates aspects of claims 1, 11, and 18 concerning a USB-based charger and adjusting voltage. However, 8610397's focus on identifying both device and battery types and comparing their charging parameters for safe charging goes beyond simply providing a universal USB power supply with a preset voltage for a device. The 8610397 patent explicitly states that despite the advantages of such chargers (referring to 6,184,652 and 6,362,610), "problems may still arise when different types of batteries are interchanged in different portable devices" because "these parameters may not always match with those of a given portable device," potentially causing damage.

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.