PTAB

IPR2014-01540

Toledo & Co Inc v. Master Lock Co LLC

Key Events

Petition

petition

Title: Padlock With Protective Sleeve and Method of Making Same
Brief Description: The ’085 patent relates to padlocks designed for enhanced durability. The invention describes a padlock comprising a lock body, a shackle, and an outer sleeve, where the sleeve’s internal surface includes at least one longitudinally extending rib that contacts the lock body to define gaps between the sleeve and the body, purportedly for protection and support.

Prior Art Relied Upon: Miranda (Patent 6,705,134) and Best (Patent 4,444,034).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Miranda disclosed a padlock assembly with a lock body, shackle, and an outer "jacket" that meets the "sleeve" limitation of claim 1. However, Petitioner contended Miranda’s jacket lacked the claimed internal, longitudinally extending rib that creates gaps. To supply this missing element, Petitioner pointed to Best, which disclosed a key-removable core with a control sleeve having a wide longitudinal rib. This rib was shown to engage the surface of the lock core, thereby creating a gap between the sleeve and the core.
- Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references as both relate to the technical field of locks. The motivation was to incorporate Best's known rib feature into the sleeve of Miranda’s padlock. Petitioner argued that using ribs to create gaps for manufacturing tolerances was a well-known, simple design choice, and its application here would have been an obvious modification to improve a similar device.
- Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying a known element (a rib) for its known function (creating a gap), yielding the predictable result of a gapped sleeve on a padlock.

Prior Art Relied Upon: Dowe (Patent 1,020,891).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Dowe, issued in 1912, disclosed every element of claim 21. Petitioner mapped Dowe’s series of stacked "tumblers" and "stumps" to the claimed "lock body comprising a stack of plates." Further, Dowe’s external "casing" was argued to function as the claimed sleeve, with sections of the casing forming a first end cap and its secured "base" forming a second end cap. A screw disclosed in Dowe for holding the stumps in position was identified as the "longitudinally extending fastener" that secured the base (end cap) to the lock body.

Prior Art Relied Upon: Miranda (Patent 6,705,134).
Core Argument for this Ground:
- Prior Art Mapping: As a separate ground, Petitioner argued that Miranda also anticipated all limitations of claim 21. Petitioner mapped Miranda’s disclosure of a lock body comprised of a "plurality of body plates" to the "stack of plates" limitation. Miranda’s external "jacket" was asserted to be the claimed "sleeve," its "top face" and "bottom face" were the claimed "first and second end cap portions," and its "cylindrical body pins" were the "longitudinally extending fastener" assembled with the plates and securing the end caps to the lock body.

Prior Art Relied Upon: Miranda (Patent 6,705,134) and Zhilong (CN 2,556,325 Y).
Core Argument for this Ground:
- Prior Art Mapping: Presented as an alternative, this ground asserted that if Miranda was found not to disclose the end cap limitations, the combination with Zhilong would render claim 21 obvious. Petitioner argued Miranda taught the foundational padlock with a stacked-plate body. Zhilong was introduced to teach a laminated padlock where the upper and lower sides are cased with a "protection sleeve," which Petitioner argued met the "end cap" limitations.
- Motivation to Combine: A POSITA would combine the references to add the known protective features of Zhilong's sleeve and end caps to Miranda's padlock. This was framed as a combination of familiar elements according to known methods to achieve the predictable and desirable result of enhanced padlock protection.
- Expectation of Success: The combination was argued to be a straightforward integration of known components for their intended purposes, leading to a high expectation of success.

Petitioner proposed constructions for several terms under the broadest reasonable interpretation standard, arguing they were critical to mapping the prior art. Key proposed constructions included:
- "sleeve": a member that at least partly covers the lock body.
- "end cap": a member adjacent to the end portion of the lock body, which may be integral with the sleeve.
- "rib": a protruding member that engages a surface to create a gap between two structures.

Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1 and 21 of the ’085 patent as unpatentable.