PTAB

IPR2016-01755

Robert Bosch Tool Corp v. SD3 LLC

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1. Case Identification

2. Patent Overview

  • Title: Power Equipment with Detection and Reaction Systems
  • Brief Description: The ’450 patent discloses safety systems for power equipment, such as table saws. The system includes a detection subsystem configured to detect a dangerous condition (e.g., a user’s body part in proximity to or in contact with a cutting tool) and a reaction subsystem configured to pivot the cutting tool away from the cutting region upon detection of the dangerous condition.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 3, and 9 under 35 U.S.C. §102

  • Prior Art Relied Upon: Nieberle (DE 19609771).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nieberle, which discloses an active safety system for circular saws, teaches every limitation of claims 1, 3, and 9. Nieberle’s “hand recognition sensor” was asserted to be the claimed “detection system,” as it uses capacitive sensing to detect when a hand reaches a defined proximity to the saw blade. Nieberle’s “saw blade pivoting device” was argued to be the claimed “reaction system,” which uses a pneumatic cylinder to “abruptly pull[] down the motor with the saw blade” so that it “completely disappears beneath the workbench.” Petitioner contended this action constitutes pivoting the cutting tool away from the cutting region. The proximity detection of Nieberle’s sensor was argued to meet the specific limitation of claim 3. For claim 9, Petitioner argued that a physical “stop to limit the pivoting” is an inherent feature of Nieberle’s emergency lowering device, as any such mechanical system must have a physical limit to its range of motion.

Ground 2: Obviousness of Claim 2 over Nieberle in view of Friemann

  • Prior Art Relied Upon: Nieberle (DE 19609771), Friemann (Patent 3,858,095).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 2, which recites that the dangerous condition is actual “contact between a person and the cutting tool.” Petitioner asserted that Nieberle teaches a proximity-based detection system. To meet the “contact” limitation, Petitioner relied on Friemann, which discloses a safety system for a band saw that uses a capacitive circuit to detect when a person touches the blade, triggering a brake.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to modify Nieberle’s system to use a contact-based sensor like Friemann’s. Proximity and contact detection were presented as known, interchangeable design choices in the field of machine safety. A POSITA would have recognized the benefit of using contact detection to avoid false positives in applications where an operator’s hands are intended to be close to the cutting tool, a scenario where a proximity sensor could be continually and improperly triggered.
    • Expectation of Success: Petitioner asserted that swapping one known type of capacitive sensor (proximity) for another (contact) involved only basic engineering work and that a POSITA would have had a reasonable expectation of successfully implementing the combination.

Ground 3: Obviousness of Claim 11 over Nieberle in view of Fergle and Shapiro

  • Prior Art Relied Upon: Nieberle (DE 19609771), Fergle (Patent 3,547,232), Shapiro (Patent 5,205,069).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground challenged claim 11, which depends from claim 1 and adds the limitation that “the reaction system includes an explosive.” Nieberle’s reaction system uses a pneumatic actuator. Petitioner argued it would have been obvious to replace this with an explosive actuator as taught by Fergle or Shapiro. Fergle discloses an explosive gas-actuated safety brake, and Shapiro discloses a high-speed safety door where a piston is restrained by an explosive bolt that splits to release the door in an emergency.
    • Motivation to Combine: The primary motivation was to increase the speed and effectiveness of the reaction system. Petitioner contended that a POSITA, seeking to create the fastest possible retraction of the saw blade to minimize injury, would have looked to known methods for high-speed actuation. Explosive actuators, as shown in Fergle and Shapiro and used in other safety applications like automotive airbags, were well-known in the art for achieving reactions on the order of milliseconds. Therefore, a POSITA would combine Nieberle’s general safety system with the explosive actuator of Fergle or Shapiro to achieve a faster, more reliable reaction.
    • Expectation of Success: Petitioner argued that substituting one known type of actuator (pneumatic) for another known, faster type (explosive) was a simple and predictable design choice for a POSITA and would yield the expected result of a faster blade retraction.

  • Additional Grounds: Petitioner asserted that claims 1 and 3 are also obvious over Nieberle in view of the ordinary knowledge of a POSITA, arguing that even if Nieberle does not explicitly teach pivoting, modifying its retraction mechanism to use a common pivoting structure would have been an obvious design choice. Petitioner also challenged claims 9 and 10 as obvious over Nieberle and Shapiro, arguing the inclusion of a stop with impact-absorbing material was common sense for a high-speed retraction mechanism to prevent damage.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 and 9-11 of the ’450 patent as unpatentable.