PTAB

IPR2015-00958

J Squared Inc v. Sauder Mfg Co

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Chair with Coupling Companion Stool Base
  • Brief Description: The ’136 patent discloses a convertible furniture combination consisting of a chair and a separate stool base. The chair can be detachably coupled to the base for use as a stationary chair, or it can be disconnected and used independently, at which point its base legs are structured to function as rockers.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, 5, 8, 9, and 11 are obvious over Yu in view of Mackey

  • Prior Art Relied Upon: Yu (Patent 6,554,353), Mackey (Patent 794,461).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yu disclosed a reconfigurable chair detachably mounted on a stool base, meeting all limitations of independent claim 1 except for the final limitation requiring base legs "structured so as to function as rockers." Petitioner asserted that Mackey, which teaches a reconfigurable chair with rockers designed for removable mounting on a base, supplied this missing element.
    • Motivation to Combine: A POSITA would combine Yu and Mackey by modifying Yu’s chair to include rockers as taught by Mackey. Petitioner contended this was a simple substitution of a known element to gain the predictable and desirable benefit of a rocking function. The motivation stemmed from common sense and Mackey’s explicit teaching of a removable rocking chair section.
    • Expectation of Success: As the combination involved applying a known mechanical feature (rockers) to a known chair design, a POSITA would have had a high expectation of success in achieving a functional, rocking convertible chair.

Ground 2: Claims 6, 7, 10, and 12-14 are obvious over Yu, Mackey or Clark, and Kassai

  • Prior Art Relied Upon: Yu (Patent 6,554,353), Mackey (Patent 794,461) or Clark (Patent 4,285,543), and Kassai (Patent 4,723,813).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Yu with a rocker reference (Mackey or Clark) to address dependent claims requiring a latching mechanism. Yu used a bolted connection to secure the chair to the base. Petitioner argued that Kassai disclosed suitable pivoting latches used to secure a tray to a high chair, which meets the "latch" and "means for releasably engaging" limitations of claims 6 and 12, respectively.
    • Motivation to Combine: A POSITA would be motivated to substitute Kassai’s latch for Yu's bolted connection to make the conversion between configurations easier, faster, and more convenient. This modification was presented as the simple substitution of one known fastener type for another to obtain a predictable improvement in usability.
    • Expectation of Success: Replacing bolts with a well-understood latch mechanism to achieve easier removal is a routine design modification with a predictable outcome.

Ground 3: Claims 1, 2, 4-8, and 10-14 are obvious over Lutes, alone or in view of Mackey

  • Prior Art Relied Upon: Lutes (Patent 2,530,474), and optionally Mackey (Patent 794,461).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Lutes disclosed a convertible chair that mounts alternatively on a stool or on a separate rocker frame, meeting nearly all limitations of the challenged claims. The key distinction was that Lutes’s rockers were on a separate, modular frame rather than being integral to the chair's base legs. Petitioner argued that Lutes’s modular rocker frame itself met the claim limitation of an "assembly positioned below said sitting portion... structured so as to function as rockers."
    • Motivation to Combine: If Lutes’s modular frame was deemed insufficient, Petitioner argued it would have been an obvious design choice to modify Lutes by permanently attaching the rockers to the chair. This would simplify the conversion process, a known advantage. The teachings of Mackey were cited as reinforcing the desirability of a rocking chair that is removable from a base, further motivating a POSITA to create a more integrated design like that claimed.
    • Expectation of Success: Modifying a chair with removable rockers to one with permanent rockers was argued to be a predictable design variation.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 1, 2, 4, 5, 8, 9, and 11 over Yu in view of Clark (using Clark instead of Mackey for the rocker teaching) and claims 6, 7, 10, and 12-14 over Yu/Mackey/Clark in further view of Gottfried (using Gottfried instead of Kassai for the latch teaching), relying on similar substitution rationales.

4. Key Claim Construction Positions

  • "function as rockers" (claim 1): Petitioner argued this functional language, added during prosecution to overcome a rejection, should be construed broadly to mean "enable rocking." Petitioner contended this construction is broader than the more structural term "are rockers" and covers any structure capable of performing the function, such as curved rails or pivoting flat rails.
  • "latch moving between closed and open positions" (claim 6): Petitioner asserted this requires only a latch, as the "moving" function has no patentable weight. The term "latch" itself should be construed broadly to include any device that holds something in place, including by entering a notch or cavity, and is not limited to a specific structure.
  • "means for releasably engaging" (claim 12): Petitioner noted that the Patent Owner, in related litigation, asserted this term is not a means-plus-function limitation under §112, ¶6. Accordingly, Petitioner argued the term should be given its broadest reasonable interpretation to encompass any manually operable chair-to-base coupling mechanism, such as the latch disclosed in Kassai or Gottfried.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, and 4-14 of the ’136 patent as unpatentable.