<em> Qualcomm Inc. v. Intel Corp. </em>

Qualcomm v. Intel involves a dispute between the two technology companies over the validity of a Qualcomm patent. The patent protects an efficient method of voltage regulation that is vital for mobile phone processors. The Federal Circuit invalidated the patent after Intel successfully proved that the patent was obvious in light of previously published information.

Intel and Qualcomm are two of the largest technology companies in the world. Both companies, based in California, specialize in manufacturing computing components, including processors and semiconductors. While Qualcomm specializes in mobile phone processors, Intel is an industry leader in computer processors. Qualcomm and Intel have a complex relationship, with Qualcomm wanting to purchase Intel until late last year, even amidst several ongoing legal battles between the two companies. Although Qualcomm is the larger company, with a market cap of around $173 billion, Intel is a giant in its own right with a current market cap of around $102 billion, even after its stock price decreased by roughly 60% in 2024. Qualcomm’s economic dominance has not stopped Intel from filing lawsuits against Qualcomm, challenging the validity of several of Qualcomm’s patents. One of the most recent lawsuits involves the validity of a Qualcomm patent for a power supply apparatus that allows for more efficient and cost-effective circuits in processors. The outcome of this case will likely have significant implications for the technology industry, especially with the increased demand for processors caused by recent innovations in artificial intelligence.

Qualcomm Inc. v. Intel Corp. involves a dispute over the validity of Qualcomm’s  patent US9608675B2 (‘675 Patent), entitled "Power Tracker for Multiple Transmit Signals Sent Simultaneously." The ‘675 patent protects a technique for generating and regulating a power supply that controls voltages in an electrical circuit in mobile phones. Regulating voltages within a circuit is vital for mobile phones and computer technology like processors. Previous methods of regulating the power supply of a circuit required multiple transmitters to create multiple signals to regulate the voltages within a circuit. The method protected by the ‘675 Patent increases the efficiency of voltage regulation by transmitting multiple signals through a single transmitter. This method also reduces the number of circuits needed within processors, which lowers production costs. 

Intel challenged Qualcomm’s ‘675 patent with six inter partes review (“IPR”) petitions on the grounds that the patent is obvious. The Patent and Trademark Appeal Board (“PTAB”) of the United States Patent and Trademark Office assesses a patent’s validity during an IPR.  Under 35 U.S.C § 103, a patent can only be obtained for inventions that are not obvious when viewed against any information that was publicly available before the patent application was filed. Intel supported four of its IPR claims of obviousness with European Patent Application Publication 2,442,440 A1 (Patent A1). For its other two IPR claims, Intel relied on a research paper by Wenhua Chen et al., called Hybrid Envelope Tracking for Efficiency Enhancement in Concurrent Dual-Band PAs, (“Research Paper”). Patent A1 and the Research Paper describes a similar system of achieving a more efficient voltage regulation using fewer signal transmitters as the ‘675 Patent. Qualcomm contended that Patent A1 and the Research paper did not invalidate Patent ‘675 because it would not have been obvious to apply the systems in Patent A1 and the Research to mobile phones as Patent ‘675 does. The PTAB ruled in favor of Intel on all six of its IPR claims, making the ‘675 Patent obvious and invalid. Qualcomm appealed the PTAB’s decision. On appeal, the PTAB upheld Intel's claims of obviousness based on Patent A1, but only for claims 1-5, 17-25, and 27-33 of Patent ‘675. The PTAB invalidated Intel’s other claims based on Chen’s research paper. Qualcomm and Intel both appealed the second decision of the PTAB to the Federal Circuit Court of Appeals.

The Federal Circuit Court of Appeals agreed with the PTAB, affirming the ruling of obviousness for claims 1-5, 17-25, and 27-33 of Patent ‘675 based on Patent A1 on September 23, 2024. The Federal Circuit noted that because Patent AI disclosed a mobile-terminal-appropriate system for controlling the supply voltage of a power amplifier, it would be obvious to apply this system to a mobile phone like Patent ‘675 does. This ruling opens the door for Intel and other technology companies to use the power regulation method described in Patent ‘675. If an invention is deemed to be obvious, it may be used by any member of public or any corporation for their own benefit as it cannot receive patent protection. Therefore, the ruling in Qualcomm v. Intel could result in an increase in the manufacturing of more efficient processors using previously protected signal techniques contained in Patent ‘675 which can be used to further fuel AI developments and innovation.