PTAB

IPR2015-00266

Product Miniature Inc v. Pop Displays USA LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Low Voltage Display Assembly
  • Brief Description: The ’935 patent discloses a low voltage display assembly for retail environments. The system uses a pair of energized, slotted conductive standards and conductive shelf support brackets to deliver power to an illumination structure, such as an LED array, thereby eliminating the need for a separate wiring system to each shelf.

3. Grounds for Unpatentability

Ground 1: Obviousness over Griesshammer - Claims 1, 2, 5, and 6 are obvious over Griesshammer.

  • Prior Art Relied Upon: Griesshammer (EP Patent No. 1 688 070).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Griesshammer, a reference not considered during prosecution, discloses all elements of the challenged claims. It teaches a low voltage illuminated display with conductive vertical supports (standards) having slots, conductive brackets, a low voltage power supply, and an illumination structure with LEDs. Crucially, Petitioner asserted that Griesshammer’s teaching that the standards "are provided with a protective or decorative surface coating" directly reads on the "insulating rail cover" limitation. This limitation was the key feature added during prosecution to overcome prior art rejections and was the examiner’s stated reason for allowance.
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference, arguing it inherently contains all claim elements or renders them obvious. Petitioner argued it would be an obvious design choice to provide slots in Griesshammer's surface coating that align with the slots in the underlying standards to allow the brackets to make electrical contact, as this is necessary for the system to function as described.
    • Expectation of Success (for §103 grounds): A POSITA would have expected success as Griesshammer describes a complete, functional system where the coating does not hinder the electrical connection between the supports and brackets.

Ground 2: Obviousness over Piepszownik in view of Ter-Hovhannisian - Claim 1 is obvious over Piepszownik in view of Ter-Hovhannisian.

  • Prior Art Relied Upon: Piepszownik (FR Patent No. 2 731 885) and Ter-Hovhannisian (Patent 7,121,675).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Piepszownik, also not before the examiner, teaches a conventional low voltage display with all major components of claim 1, including conductive posts (standards), conductive brackets, and an "insulating material" that covers the posts except at contact points, thus teaching the "insulating rail cover." Piepszownik discloses a "low-voltage fluorescent tube" as its illumination source. Ter-Hovhannisian was cited for its disclosure that LEDs are typically assembled on a printed circuit board for use in display systems.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Piepszownik’s display system with Ter-Hovhannisian’s LED circuit board illumination structure to replace the outdated fluorescent tube. The motivation stemmed from the well-known advantages of LEDs, including higher efficiency, longer life, smaller size, and lower heat production.
    • Expectation of Success (for §103 grounds): Success was expected because substituting one known type of low-voltage light source (fluorescent tube) for another (LEDs on a circuit board) was a routine and predictable modification in the art of display design.

Ground 3: Obviousness over Slesinger in view of Maheu - Claim 3 is obvious over Slesinger in view of Maheu.

  • Prior Art Relied Upon: Slesinger (Patent 6,231,205) and Maheu (Patent 7,798,338).

  • Core Argument for this Ground:

    • Prior Art Mapping: Slesinger, which was a primary reference during prosecution, was argued to teach most elements of claim 3, including the low voltage power supply, wiring harness, conductive standards, and conductive brackets. However, it lacked the specific mounting structure for attaching the display to a gondola wall. Maheu was introduced to supply this missing element, as it discloses a "universal mounting bracket" with a horizontal member and axially spaced prongs designed specifically for attaching displays to conventional retail pegboards.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Maheu's mounting bracket with Slesinger's display for the simple purpose of adapting the display for use in its intended retail environment. Slesinger states its display is for retail use, and Maheu explains that such displays are typically attached to common structures like perforated panel boards (pegboards).
    • Expectation of Success (for §103 grounds): A POSITA would expect success in attaching a known mounting bracket to a known display system, as this represented a straightforward mechanical integration of conventional components for their intended purpose.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claim 3 over Griesshammer and Maheu; claims 4 and 7 over Piepszownik; and claim 5 over Griesshammer and Slesinger. These grounds relied on similar prior art teachings and combination rationales as those detailed above.

4. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner argued that a person of ordinary skill in the art (POSA) would have a working knowledge of industry safety standards, specifically UL standards such as UL 2108 ("Low Voltage Lighting Systems"). These standards require the enclosure of current-carrying parts to prevent fire or shock. This industry knowledge would have independently motivated a POSA to add a protective, insulating cover over the conductive standards of any prior art display system, reinforcing the argument that the "insulating rail cover" limitation was an obvious safety feature.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of the ’935 patent as unpatentable.