PTAB

IPR2017-00126

One World Technologies Inc v. Chamberlain Group Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Movable Barrier Operator With Retrofitted Passive Infrared Detector
  • Brief Description: The ’319 patent discloses a garage door opener system where a "wall console" (control unit) is equipped with a passive infrared (PIR) detector. This wall console, which includes a microcontroller, communicates with a microcontroller in the motor drive unit (head unit) via a digital data bus to control functions such as door movement and illumination.

3. Grounds for Unpatentability

Ground 1: Obviousness over Doppelt, Jacobs, Admitted Art, and Gilbert - Claims 1-4, 7-12, 15, and 16 are obvious over Doppelt in view of Jacobs, Admitted Art, and Gilbert.

  • Prior Art Relied Upon: Doppelt (U.K. Patent Application GB 2312540), Jacobs (Patent 5,467,266), Gilbert (Patent 5,530,896), and Admitted Art from the ’319 patent specification.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the primary reference, Doppelt, discloses a conventional garage door opener system with a motor drive unit (head unit) containing a microcontroller and a separate wall-mounted switch. However, Doppelt’s wall switch lacks a microcontroller or a PIR detector. To supply these missing elements, Petitioner mapped teachings from the secondary references. The Admitted Art of the ’319 patent itself concedes that using PIR detectors in garage door systems to detect a person was well-known. Jacobs teaches a system for a different movable barrier (a motorized window panel) that includes wall-mounted control panels containing their own microcontrollers and occupancy detectors, which communicate with a motor controller via a wired serial link bus (a digital data bus). Gilbert further teaches a general home automation system where control units with microcontrollers communicate with working appliances (e.g., motors, lamps) having their own microcontrollers over a hardwired, bidirectional communication path.
    • Motivation to Combine: A POSITA would combine these references to solve known problems and create a predictable system. The primary motivation was to address the safety hazard identified in Doppelt—a person being left in a dark garage—by incorporating a well-known PIR detector (as taught by the Admitted Art) to automatically control the light. A POSITA would look to an analogous field, such as the motorized barrier system in Jacobs, to learn how to implement a wall-mounted control with an occupancy detector and a microcontroller. Jacobs provides the blueprint for connecting the enhanced wall console to the motor drive unit using a digital data bus. The combination was presented as a simple substitution of known elements (a PIR sensor and microcontroller in a wall unit) for a conventional wall switch to gain the predictable benefits of automatic light control and enhanced functionality.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. The integration of well-known components like microcontrollers, PIR detectors, and digital data buses into a garage door opener system involved applying known principles and would have yielded predictable results.

4. Key Claim Construction Positions

  • "wall console": Petitioner argued for a narrow construction of "wall console" to mean "a wall-mounted control unit including a passive infrared detector." This construction was central to its invalidity argument.
    • Petitioner contended that the patentee disavowed any broader meaning through the specification. The argument was based on three points:
      1. The specification repeatedly identifies the "principal aspect of the present invention" as retrofitting a PIR detector into the wall unit.
      2. Every embodiment and figure described in the patent depicts the wall control unit as including a PIR detector.
      3. The specification disparages prior art that located PIR detectors in the head unit, thereby distinguishing the invention based on the detector's specific location in the wall unit.
  • "controller" / "microcontroller": Petitioner argued that a "controller" is any type of control device, such as a microcontroller, and that a "microcontroller" is a microprocessor specifically designed for controlling equipment. This distinction was used to assert that analysis of the narrower claims reciting "microcontroller" (e.g., claim 1) applies equally to the broader claims reciting "controller" (e.g., claim 9).
  • "digital data bus": Petitioner argued this term should be construed as "a wired line for carrying discrete units of data between components," based on the patent's description and prosecution history, which explicitly identifies the connection as "line 62."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4, 7-12, 15, and 16 of the ’319 patent as unpatentable.