In re: Power Integrations, Inc.

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Power’s 876 patent, “Frequency Jittering Control for Varying the Switching Frequency of a Power Supply,” describes a technique for reducing electromagnetic interference noise “by jittering the switching frequency of a switched mode power supply.” Power sued Fairchild, alleging willful infringement, arguing that the term “coupled” in claim 1, in light of the specification and surrounding claim language, required two circuits to be connected in a manner “such that voltage, current or control signals pass from one to another” and that the “recited coupling” between the counter and the digital to analog converter must be “present for the purposes of control.” The court agreed, emphasizing that the term “coupled” did not “require a direct connection or . . . preclude the use of intermediate circuit elements.” The Federal Circuit affirmed a judgment of nonobviousness. The Patent and Trademark Office commenced ex parte reexamination. The board affirmed the examiner’s rejection of claim 1 as anticipated. The Federal Circuit vacated, stating that the board is not generally bound by a prior judicial claim construction and, in reexamination applies a different claim construction standard but that because Power's principal argument was tied to the court’s claim construction, the board was obligated to evaluate that construction and determine whether it was consistent with the broadest reasonable construction. On remand, the board again affirmed the examiner’s rejections. The Federal Circuit reversed, finding that the board’s rejections were based on an unreasonably broad claim construction. View "In re: Power Integrations, Inc." on Justia Law