PTAB

IPR2017-00126

One World Technologies, Inc. d/b/a Techtronic Industries Power Equipment v. The Chamberlain Group, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Movable Barrier Operator with Retrofitted Passive Infrared Detector
  • Brief Description: The ’319 patent describes a garage door opener system featuring a wall console that includes a passive infrared (PIR) detector. The system is designed to allow for the PIR detector to be easily retrofitted to an existing garage door operator to control functions, such as illumination, using the existing wiring between the wall console and the main motor drive unit.

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/or Gilbert.

  • Prior Art Relied Upon: Doppelt (U.K. Patent Application GB 2312540), Jacobs (Patent 5,467,266), Gilbert (Patent 5,530,896), and Admitted Prior Art from the ’319 patent specification.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Doppelt disclosed a garage door opener system nearly identical to that of the ’319 patent, including a motor drive unit (head unit) with a microcontroller connected by wire to a wall switch. However, Doppelt’s wall switch lacked a PIR detector and a dedicated microcontroller. Petitioner asserted that the ’319 patent itself admitted it was well-known to use PIR detectors in garage door systems for detecting a person’s presence (Admitted Art). To supply the missing elements, Petitioner pointed to Jacobs, which taught a wall-mounted control panel for a motorized barrier (a window panel) that included its own microcontroller, an occupancy detector, and communicated with the motor controller via a digital data bus. Petitioner also relied on Gilbert, which taught connecting home appliances (like motors) having microcontrollers with remote control units (also with microcontrollers) via a bidirectional wired communication path to create more advanced and convenient control systems. By combining these teachings, a person of ordinary skill in the art (POSITA) would have arrived at the claimed invention.
    • Motivation to Combine: A POSITA would combine these references for several reasons.
      • A POSITA would modify Doppelt to address the safety hazard it described—a person being left in a dark garage—by incorporating a PIR detector, a well-known solution for presence detection acknowledged in the Admitted Art.
      • A POSITA would look to Jacobs because it operates in the same field of motor-driven barriers and provides an integrated solution for a wall control with an occupancy detector and a microcontroller. Adding the microcontroller from Jacobs to Doppelt’s wall unit was a known way to improve utility by adding advanced controls and programmable features.
      • A POSITA would be motivated to use the digital communication taught by Jacobs and Gilbert, as it was a well-known trend to replace analog signaling with more efficient and robust digital communication between system components like a wall console and a motor drive unit.
    • Expectation of Success: Petitioner contended that a POSITA would have had a high expectation of success. The combination involved applying known technologies (PIR detectors, microcontrollers in wall units, digital data buses) to a conventional system (Doppelt’s garage door opener) to achieve predictable benefits, such as improved safety and enhanced functionality. Combining these well-known components was presented as a trivial task using standard techniques.

4. Key Claim Construction Positions

  • "wall console": Petitioner argued this term should be construed as a "wall-mounted control unit including a passive infrared detector."
    • This proposed construction was central to Petitioner's invalidity argument. Petitioner asserted that the Patent Owner had disavowed any broader scope through statements in the specification and actions during prosecution.
    • The argument was based on the specification repeatedly describing the "principal aspect of the present invention" as including a PIR detector in the wall unit, showing this feature in every embodiment, and disparaging prior art systems that placed the PIR detector in the motor head unit instead of the wall unit.
    • By limiting the claim scope through this construction, Petitioner aimed to establish that the primary reference, Doppelt, did not teach a key element of the claim, thereby framing the analysis as whether it would have been obvious to add the PIR detector to Doppelt’s wall unit.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-4, 7-12, 15, and 16 of the ’319 patent as unpatentable under 35 U.S.C. §103.