Fantasia Trading v. CogniPower: Federal Circuit Affirms Power Converter Patents Valid
Fantasia Trading, LLC sought to cancel two CogniPower reissue patents covering demand pulse isolation in power converters, but the Federal Circuit affirmed their validity in a per curiam Rule 36 judgment. The appeal ran 576 days before closing, leaving both RE47031 and RE47713 fully intact.
Federal Circuit affirms CogniPower’s reissue patents in power electronics dispute
Fantasia Trading, LLC initiated this appeal at the Court of Appeals for the Federal Circuit (Case No. 22-2008) on 13 July 2022, challenging the patentability of two CogniPower, LLC reissue patents: RE47031 and RE47713. Both patents relate to power converter technology employing demand pulse isolation — a control architecture relevant to efficient switched-mode power conversion. The case was heard by a panel comprising Chief Judge Moore, Judge Stoll, and Judge Bencivengo.
The Federal Circuit issued a per curiam affirmance on 9 February 2024 under Federal Circuit Rule 36, confirming the lower tribunal’s findings without a written opinion. The basis of termination is recorded as ‘Patent Upheld,’ meaning CogniPower’s RE47031 and RE47713 survived the invalidity or cancellation challenge brought by Fantasia Trading. Rule 36 affirmances carry full precedential weight as to the outcome, even without explanatory reasoning.
The 576-day duration is consistent with typical Federal Circuit appeal timelines for inter partes review or post-grant proceedings. The use of Rule 36 — a summary affirmance — suggests the panel found no reversible error warranting extended written analysis, which typically signals the lower tribunal’s validity findings were well-supported. What remains unknown from the public record is the precise PTAB proceeding underlying this appeal and whether any claim narrowing occurred during reissue prosecution.
Filing to settlement in 576 days
576 days from filing to Federal Circuit judgment
Federal Circuit affirms both CogniPower patents valid under Rule 36
What a Rule 36 affirmance means in practice
Federal Circuit Rule 36 allows the court to affirm a lower tribunal’s decision without issuing a written opinion when it determines the judgment is correct and no precedential value would be added by elaboration. This is not a rubber stamp — the panel must affirmatively agree the outcome is correct. For CogniPower, it signals that the validity of RE47031 and RE47713 was sufficiently clear on the record to require no further judicial explanation.
Affirmance without opinionBoth reissue patents survive the invalidity challenge intact
The ‘Patent Upheld’ basis of termination confirms that neither RE47031 nor RE47713 was cancelled or materially limited by this proceeding. Reissue patents already reflect USPTO-approved scope corrections from original grants; surviving a subsequent invalidity challenge at appeal strengthens their enforceability posture. Any third party that relied on the appeal outcome to avoid licensing exposure will need to reassess that position.
Full validity confirmedPatentability verdict cause points to a post-grant origin
The verdict cause is recorded as an invalidity or cancellation action, consistent with an appeal from a PTAB inter partes review or post-grant review proceeding. In this procedural posture, Fantasia Trading bore the burden of demonstrating unpatentability by a preponderance of evidence. The Federal Circuit’s affirmance means that burden was not met at the PTAB level, and the appeal did not change that finding.
Post-grant review originCogniPower retains enforceable IP over demand pulse isolation
With both patents affirmed valid, CogniPower holds strengthened IP covering power converter architectures using demand pulse isolation. Competitors and supply-chain participants — including those in consumer electronics power adapters and similar AC/DC conversion markets — should treat these patents as active enforcement risks. Fantasia Trading, as a named challenger, now faces estoppel constraints that may limit further validity attacks on the affirmed claims.
Enforcement risk elevatedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Fantasia Trading, LLC | Company | Validity challenger — petitioned to cancel CogniPower’s reissue power converter patentsSearch in Eureka ↗ |
| Defendant | CogniPower, LLC | Company | CogniPower, LLC — holder of reissue patents RE47031 and RE47713 in power conversion technologySearch in Eureka ↗ |
| Plaintiff counsel | Brian P. Boyd | Attorney | Counsel for Fantasia Trading, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Frank Scherkenbach | Attorney | Counsel for Fantasia Trading, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Howard G. Pollack | Attorney | Counsel for Fantasia Trading, LLCSearch in Eureka ↗ |
| Plaintiff counsel | John Winston Thornburgh | Attorney | Counsel for Fantasia Trading, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Michael R. Headley | Attorney | Counsel for Fantasia Trading, LLCSearch in Eureka ↗ |
| Defendant counsel | Jason Sheasby | Attorney | Counsel for CogniPower, LLCSearch in Eureka ↗ |
| Defendant counsel | Jonathan M. Lindsay | Attorney | Counsel for CogniPower, LLCSearch in Eureka ↗ |
| Defendant counsel | Philip J. Warrick | Attorney | Counsel for CogniPower, LLCSearch in Eureka ↗ |
| Presiding judge | Judge / | Chief Judge | Court of Appeals for the Federal Circuit — Chief JudgeSearch in Eureka ↗ |
Stipulation of dismissal — official text
The per curiam affirmance under Federal Circuit Rule 36 is terse by design: it conveys that the three-judge panel unanimously agreed the lower tribunal’s ruling required no correction, but provides no claim construction, no discussion of prior art, and no limiting analysis. For CogniPower, this is the strongest possible appellate outcome short of a written opinion in their favour. For third parties, the absence of written reasoning means FTO conclusions cannot be drawn from appellate claim interpretation — original patent claims and PTAB proceedings remain the primary reference documents.
RE47031 & RE47713 — Demand Pulse Isolation Power Converter Patents
RE47031 (application US15/090929) and RE47713 (application US15/168998) are reissue patents held by CogniPower, LLC, covering power converter technology that employs demand pulse isolation as a control mechanism. Reissue patents are granted by the USPTO to correct defects in original patents; their claims may be broadened or narrowed relative to the original grant. The products at issue are described as ‘power converter with demand pulse isolation,’ a topology relevant to efficient, low-loss AC/DC and DC/DC power conversion widely deployed in consumer electronics, industrial power supplies, and charging infrastructure.
The survival of these patents through PTAB and Federal Circuit review signals that CogniPower’s claim architecture is sufficiently differentiated from prior art to withstand adversarial scrutiny. For competitors operating in switched-mode power supply design — particularly those sourcing or manufacturing power adapters, chargers, or embedded power modules — these patents represent active IP that has demonstrated litigation resilience. The dual-reissue structure suggests deliberate prosecution strategy to optimise claim scope, warranting close analysis of claim language before product development proceeds.
Should your power converter products be cleared against RE47031 and RE47713?
Any organisation designing, manufacturing, or importing power converters that implement demand pulse isolation or closely related control architectures should treat RE47031 and RE47713 as live FTO concerns. The Federal Circuit’s affirmance removes the near-term prospect of these claims being cancelled, meaning the risk window for potential infringement is extended. This is particularly relevant for companies in consumer electronics power supply chains, EV charging components, and industrial power conversion equipment.
PatSnap Eureka’s FTO Search Agent can map the claim language of RE47031 and RE47713 against your product specifications, flag related family members and pending continuations, and alert you to new filings in CogniPower’s portfolio that could extend the claim perimeter. Ongoing claim monitoring through Eureka ensures your R&D and procurement teams receive early warning before a new enforcement action changes the competitive landscape.
Run a freedom-to-operate analysis on RE47031 to assess your product’s exposure
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What this case signals for the power electronics IP landscape
A Rule 36 affirmance of two reissue patents strengthens CogniPower’s enforcement position and raises the cost of future validity challenges in this technology space.
Reissue patents that survive appeal carry heightened litigation credibility
RE47031 and RE47713 have now cleared PTAB scrutiny and Federal Circuit review. For licensing negotiations and future infringement actions, CogniPower can point to a clean appellate record. Defendants in future suits face a more difficult invalidity argument given the estoppel implications for related parties and the persuasive weight of the affirmance.
Rule 36 outcomes leave claim scope interpretation open
Because the Federal Circuit issued no written opinion, no judicial claim construction is on record from this appeal. This creates residual uncertainty around the precise boundaries of the asserted claims — relevant for any FTO analysis or design-around strategy. Product teams should not assume the affirmed claims have narrow scope simply because the ruling was summary.
Fantasia v CogniPower — key questions answered
The Federal Circuit affirmed the lower tribunal’s ruling in favour of CogniPower on 9 February 2024, upholding the validity of reissue patents RE47031 and RE47713. The affirmance was issued per curiam under Federal Circuit Rule 36, meaning no written opinion was provided. Both patents covering demand pulse isolation power converter technology remain valid and enforceable.
A Rule 36 affirmance means the Federal Circuit panel unanimously agreed the lower tribunal’s decision was correct, but declined to issue a written opinion. It carries full legal effect as an affirmance — the patents are upheld. However, it provides no judicial claim construction or analysis of prior art, leaving scope questions to be resolved from the underlying patent and PTAB record.
RE47031 and RE47713 are reissue patents covering power converter technology that uses demand pulse isolation as a control architecture. This approach is relevant to switched-mode power supplies used in consumer electronics chargers, industrial power modules, and similar AC/DC or DC/DC conversion applications. Both patents originate from applications filed in the US15/090929 and US15/168998 series respectively.
Fantasia Trading, LLC was the appellant challenging CogniPower’s patents in what appears to be an appeal from a PTAB post-grant proceeding based on the invalidity/cancellation cause of action. As the losing petitioner, Fantasia Trading is likely subject to statutory estoppel under 35 U.S.C. § 315(e), which would bar it from asserting in future litigation grounds that were raised or reasonably could have been raised during the proceeding.
Reissue patents have been reviewed and amended by the USPTO to correct errors or optimise claim scope in the original grant. They can carry broader or narrower claims than the original patent. Surviving both PTAB validity review and a Federal Circuit appeal significantly strengthens their enforceability, making them harder to challenge in future infringement litigation and more credible in licensing negotiations.
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