Nera Innovations Limited v. John A. Squires, Under Secretary of Commerce for Intellectual Property

NOTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
NERA INNOVATIONS LIMITED,
Appellant
v.
JOHN A. SQUIRES, UNDER SECRETARY OF
COMMERCE FOR INTELLECTUAL PROPERTY
AND DIRECTOR OF THE UNITED STATES
PATENT AND TRADEMARK OFFICE,
Intervenor
______________________
2024-1079
______________________
Appeal from the United States Patent and Trademark
Office, Patent Trial and Appeal Board in No. IPR2022-
00573.
______________________
Decided: October 24, 2025
______________________
ROBERT A UCHTER, Auchter PLLC, Washington, DC, ar-
gued for appellant. Also represented by BRETT E. C OOPER,
BC Law Group, PC, New York, NY.
ROBERT M C BRIDE , Office of the Solicitor, United States
Patent and Trademark Office, Alexandria, VA, argued for
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NERA INNOVATIONS LIMITED v. SQUIRES 2
intervenor. Also represented by PETER J. AYERS , M ONICA
BARNES LATEEF.
______________________
Before PROST, CUNNINGHAM, and STARK , Circuit Judges.
PROST, Circuit Judge.
Nera Innovations Limited (“Nera”)1 appeals a final
written decision of the Patent Trial and Appeal Board
(“Board”) in an inter partes review brought by Apple Inc.
The Board determined all challenged claims of U.S. Patent
No. 7,825,537 (“the ’537 patent”) are unpatentable. Apple
Inc. v. Scramoge Tech. Ltd., No. IPR2022-00573, Paper 32
(P.T.A.B. Sep. 11, 2023) (“Decision”). We affirm.
BACKGROUND
The ’537 patent is directed to systems and methods for
inductively transferring power from a base unit to a target
unit. ’537 patent col. 1 ll. 50–55. It purports to “enhanc[e]
power transfer efficiency” by monitoring and adjusting op-
erating conditions of the inductive coils in the base and tar-
get units. Id. at col. 4 ll. 20–29.
In its final written decision, the Board determined the
challenged claims (i.e., claims 1–22 and 28) to be unpatent-
able based on numerous grounds including anticipation
and obviousness. In this appeal, Nera only challenges the
Board’s determinations that dependent claims 16 and 19–
22 are unpatentable for obviousness. Appellant’s Br. 4.
Nera timely appealed, and we have jurisdiction under
28 U.S.C. § 1295(a)(4)(A).
1 After this appeal was filed, the prior assignee,
Scramoge Technology Limited, transferred ownership of
the patent at issue to Nera and moved to substitute Nera
as the Appellant, which we granted.
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NERA INNOVATIONS LIMITED v. SQUIRES 3
D ISCUSSION
Nera makes two arguments on appeal: (1) the Board
erred in its construction of the “coupled” limitation, and
(2) the Board failed to articulate a sufficient motivation to
combine prior-art references Flowerdew2 and Jang.3 We
address each in turn.
“We review the Board’s factual findings for substantial
evidence and its legal conclusions without deference.” Ken-
nametal, Inc. v. Ingersoll Cutting Tool Co., 780 F.3d 1376,
1381 (Fed. Cir. 2015).
I
Nera disputes the Board’s construction of the term
“coupled” in claim 15, from which appealed claim 16 de-
pends. The limitation in question reads “a load circuit cou-
pled to said first inductive element.” ’537 patent claim 15.
The Board rejected the patent owner’s argument that “cou-
pled” is limited to an electrical connection, noting that
other claims use the term “electrically coupled,” and that
specification embodiments cannot be used to rewrite the
claim language. Decision, at 42–44. The Board found that
Flowerdew’s teaching of a “sense coil” interface, which is
inductively or magnetically coupled to the first inductive
element, meets the limitation. Id. at 40–44.
We agree with the Board. “Differences among claims
can . . . be a useful guide in understanding the meaning of
particular claim terms.” Phillips v. AWH Corp., 415 F.3d
1303, 1314–15 (Fed. Cir. 2005) (en banc). Claim 15 simply
recites “coupled,” while claims 23 and 27 recite “electrically
coupled.” This difference demonstrates that the patentee
knew how to limit the claims to an electrical connection but
chose not to do so for claim 15. Nera’s arguments that the
2 U.S. Patent No. 7,211,986 (“Flowerdew”).
3 U.S. Patent App. Pub. No. 2004/0218406 (“Jang”).
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NERA INNOVATIONS LIMITED v. SQUIRES 4
specification embodiments only describe electrical connec-
tions to the first inductive element, Appellant’s Br. 28, do
not persuade us that the term “coupled” in claim 15 is lim-
ited to an electrical connection. See Hill-Rom Servs., Inc.
v. Stryker Corp., 755 F.3d 1367, 1371 (Fed. Cir. 2014)
(“While we read claims in view of the specification, of which
they are a part, we do not read limitations from the embod-
iments in the specification into the claims.”).
Nera’s argument that claim 14’s use of the word “cou-
pling” restricts any “coupled” elements to being electrically
connected, Appellant’s Br. 25–28, is similarly unavailing.
Nera’s argument is premised on: (1) like words (e.g., “cou-
pling” and “coupled”) being interpreted alike; and (2) the
nature of the elements coupled in claim 14 necessitating an
electrical connection, because there is allegedly no other
way for the recited “DC voltage source” to be coupled to the
“first inductive element.” Even accepting Nera’s argument
that the DC voltage source and first inductive element
could only be coupled via an electrical connection, it does
not necessarily follow that a different coupling between dif-
ferent elements must also constitute an electrical connec-
tion. Claim 15 recites “a load circuit coupled to said first
inductive element.” ’537 patent claim 15 (emphasis added).
Claim 14’s “coupling,” which is between different ele-
ments—a DC voltage source and the first inductive ele-
ment—does not limit the “coupled” elements of claim 15.
We therefore affirm the Board’s construction.
II
Next, Nera argues that the Board failed to articulate a
sufficient motivation to combine Flowerdew and Jang.
Whether one of skill in the art would have been moti-
vated to combine prior-art references is a factual question
that we review for substantial evidence. Intel Corp. v.
PACT XPP Schweiz AG, 61 F.4th 1373, 1378 (Fed. Cir.
2023). “Substantial evidence is such relevant evidence as
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NERA INNOVATIONS LIMITED v. SQUIRES 5
a reasonable mind might accept as adequate to support a
conclusion.” Novartis AG v. Torrent Pharms. Ltd., 853 F.3d
1316, 1324 (Fed. Cir. 2017) (cleaned up).
Here, substantial evidence supports the Board’s deter-
mination that a skilled artisan would have been motivated
to combine Flowerdew and Jang. In its analysis, the Board
found that (1) Flowerdew’s description of its oscillator is
“simplified”; (2) Flowerdew expressly teaches that various
designs and components can be adopted to implement its
charging circuit; and (3) modifying Flowerdew’s charging
system to include Jang’s inverter would “provide a way to
implement Flowerdew’s digital driver.” Decision, at 37–38.
That is, Jang’s inverter supplies the missing implementa-
tion details for the oscillator in Flowerdew’s charger. The
disclosures of the references support these findings. E.g.,
Flowerdew col. 6 ll. 8–13 (describing the “simplified circuit
diagram shown in FIG. 2”); id. at col. 6 ll. 8–13 (“[o]ther
circuit elements and arrangement may be utilized”); id.
at col. 5 ll. 16–19 (describing controller and oscillator used
to provide “a high frequency A.C. signal to drive a charger
coil”); Jang ¶¶ [0021]–[0027] (describing inverter switches
used to provide variable current to an inductive coil).
Rather than relying on the mere fact that the elements
existed in the prior art, the Board here set forth a motiva-
tion—one would have looked to Jang for details as to how
to implement Flowerdew’s charger—that is supported by
substantial evidence, as discussed above.
CONCLUSION
We have considered Nera’s remaining arguments and
find them unpersuasive. For the foregoing reasons, we af-
firm the Board’s final written decision.
AFFIRMED
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