PTAB

IPR2015-01130

OjMar US LLC v. Security People Inc

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1. Case Identification

2. Patent Overview

  • Title: Electronic Keypad-Operated Locker Lock with Separate Manager Key Access
  • Brief Description: The ’180 patent discloses an electronic lock for temporary-use lockers, such as those in fitness centers. The system features two independent means of access: a keypad for a user to enter a self-selected code, and a separate electronic key reader that allows a manager to operate the lock using a unique electronic identification device, bypassing the user's code.

3. Grounds for Unpatentability

Ground 1: Claims 1-12 are obvious over Ziegler in view of Dawson.

  • Prior Art Relied Upon: Ziegler (Patent 5,950,458) and Dawson (Patent 6,123,456).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ziegler, which discloses an electronic keypad lock for hotel safes, teaches every element of independent claim 4 except for the separate electronic key reader for manager access. Ziegler teaches a lock with a housing, a movable bolt, a user-operated keypad, and a microcontroller. For administrative access, Ziegler uses a master code entered on the same keypad. Dawson, directed to general electronic access control systems, explicitly teaches using a separate electronic reader (for a card or fob) as a secondary, more secure means of access for administrative personnel, distinct from the primary user interface. Petitioner contended that substituting Ziegler’s master code with Dawson’s more secure electronic key reader would result in the lock claimed in the ’180 patent. The arguments for dependent claims 1-3 and 5-12 followed from the express teachings of Ziegler and Dawson concerning battery power, microcontrollers, and bolt mechanisms.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Ziegler and Dawson to solve the well-known security flaws associated with master codes. As acknowledged in the ’180 patent’s own background, master codes can be observed, and managing them with high staff turnover is problematic and requires reprogramming every lock. Dawson expressly teaches its separate key reader as a solution to these very problems in the analogous field of access control. A POSITA would therefore have been motivated to replace Ziegler’s insecure master code with Dawson’s more secure, physically-controlled electronic key system to improve security and operational efficiency.
    • Expectation of Success: The combination would have been simple and predictable. Interfacing an electronic key reader (Dawson) with the microcontroller of an electronic lock (Ziegler) was a routine matter for a POSITA at the time. Both systems relied on standard electronic components and logic, presenting no technical hurdles and ensuring a high expectation of success.

Ground 2: Claims 1-12 are obvious over Glick in view of the "Unikey System" Brochure.

  • Prior Art Relied Upon: Glick (Patent 5,887,461) and the Unikey System marketing brochure (published 1999).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Glick discloses a self-contained, battery-powered electronic locker lock with a keypad for user code entry and an electrically operated bolt. Like Ziegler, Glick relies on a master keypad code for manager access. The Unikey System brochure describes a commercially available access control system for lockers and cabinets. Critically, the brochure advertises a dual-access system featuring a user keypad and a separate "manager’s bypass key port" for use with a portable electronic key. The brochure extols the security benefits of this bypass system, including the creation of an audit trail each time the manager’s key is used. Petitioner argued the combination of Glick’s lock with the manager access system described in the Unikey brochure teaches all limitations of the challenged claims.
    • Motivation to Combine: The motivation was market-driven and explicit. The Unikey brochure provided a clear commercial reason to enhance a basic electronic lock like Glick’s. A POSITA seeking to create a more competitive and secure locker lock would have been directly motivated by the Unikey brochure to add a separate, auditable manager key system. This modification would directly address the known security and management problems of master codes by providing a superior, commercially available alternative.
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing the Unikey system’s features into the Glick lock. The Unikey brochure describes a mature, off-the-shelf technology. Integrating its key port and associated logic with Glick’s microcontroller-based lock would have been a straightforward design choice with predictable results.

Additional Grounds: Petitioner asserted additional obviousness challenges, including a combination of Ziegler, Dawson, and a third reference teaching specific motor-driven bolt mechanisms relevant to dependent claims. These grounds relied on the same core motivation to improve the security of a master-code-based lock system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of the ’180 patent as unpatentable under 35 U.S.C. §103.