PTAB

IPR2016-01754

Robert Bosch Tool Corp v. SD3 LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: POWER EQUIPMENT WITH SYSTEMS TO MITIGATE OR PREVENT INJURY
  • Brief Description: The ’279 patent relates to safety systems for power equipment, particularly woodworking machines like table saws. The technology involves a detection system to identify a dangerous condition (e.g., a user contacting the cutting tool) and a reaction system with an actuator and a moveable component that rapidly decelerates or retracts the cutting tool to prevent or mitigate injury.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nieberle - Claims 1, 5, 6, 10-14, 16, and 17 are obvious over Nieberle.

  • Prior Art Relied Upon: Nieberle (DE 196 09 771).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nieberle discloses all elements of the independent claims. Nieberle teaches a woodworking machine (a table saw) with a capacitive “hand recognition sensor” that functions as the claimed detection system to detect a dangerous proximity condition. Upon detection, Nieberle’s “emergency lowering device,” which includes a pneumatic cylinder, acts as the claimed mechanism to mitigate injury by retracting the still-rotating saw blade completely below the workbench.
    • Motivation to Combine (Modify): Petitioner contended that the final limitation—an actuator moving a component 1/32nd of an inch in approximately 3 milliseconds or less—represents an obvious optimization of Nieberle's system. A person of ordinary skill in the art (POSITA) would have understood that the severity of injury depends on the reaction time. Therefore, a POSITA would be motivated to optimize the speed of Nieberle’s pneumatic retraction system to make it as fast as possible, thereby minimizing injury. The claimed 3ms value was presented not as an unexpected result, but as a predictable outcome of routine engineering to achieve a known goal.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in modifying and optimizing Nieberle’s pneumatic actuator using known engineering principles to achieve the reaction speeds recited in the claims.

Ground 2: Obviousness over Nieberle and Bielinski - Dependent Claims 2-4 are obvious over Nieberle in view of Bielinski.

  • Prior Art Relied Upon: Nieberle (DE 196 09 771), Bielinski (Patent 5,606,889).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Nieberle reference to address claims 2-4, which specifically require the actuator to include "one or more springs." Nieberle’s actuator is pneumatic. Petitioner asserted that Bielinski remedies this deficiency by teaching a fast-acting actuator comprised of a compressed spring held by a link wire, which can be broken by an electrical current to release the spring.
    • Motivation to Combine: A POSITA seeking to implement or optimize a rapid reaction system for the device in Nieberle would have been aware of various known high-speed actuators. Bielinski explicitly teaches using a spring-loaded actuator for "initiation of motion...in a precise timed manner." Therefore, a POSITA would find it obvious to substitute Nieberle’s pneumatic actuator with Bielinski’s well-known spring-loaded actuator to achieve the desired quick retraction.
    • Expectation of Success: As spring-loaded actuators were conventional for creating rapid motion, a POSITA would have reasonably expected to successfully integrate Bielinski's actuator into the Nieberle safety system to achieve the claimed performance.

Ground 3: Obviousness over Lokey - Claims 1, 5-8, 10, and 12-15 are obvious over Lokey.

  • Prior Art Relied Upon: Lokey (Patent 3,785,230).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Lokey discloses a woodworking machine (table saw) with a "capacitance proximity sensor" where the blade is part of the circuit, meeting the "detection system" limitation. Upon detection, Lokey’s reaction system actuates a solenoid that moves a rubber brake block into contact with the saw blade, causing "virtually instantaneous" deceleration. The brake block is the claimed "moveable component" that decelerates the cutting tool.
    • Motivation to Combine (Modify): Similar to the argument against Nieberle, Petitioner contended that achieving the claimed motion (1/32nd inch in ~3ms) would be an obvious optimization of Lokey's braking system. Lokey teaches that its reaction is "virtually instantaneous," and numerous other prior art references impressed upon a POSITA the need for reaction times in the low-millisecond range to be effective. Optimizing the speed of Lokey's solenoid or replacing it with another known fast actuator was a matter of routine design choice.
    • Expectation of Success: A POSITA had tools available to make the brake react as quickly as desired and would have considered and selected from numerous known actuators (e.g., explosive actuators, loaded springs, overdriven solenoids) with a high expectation of success.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 2-4 based on combining Lokey with Bielinski, arguing a POSITA would have been motivated to replace Lokey's solenoid actuator with Bielinski's spring-loaded actuator for the same reasons articulated in Ground 2.

4. Key Technical Contentions

  • Optimization of a Result-Effective Variable: A central contention across multiple grounds was that the claimed performance limitation ("1/32nd of an inch within approximately 3 milliseconds") is not a patentable distinction over the prior art. Petitioner argued this is merely specifying a value for a known result-effective variable (reaction time). Because the prior art established that faster reaction times were desirable to mitigate injury, achieving a specific time through routine calculation and engineering is an obvious design choice, not an invention, unless it produces unexpected results, which Petitioner argued were absent here.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-8 and 10-17 of Patent 8,011,279 as unpatentable.