PTAB

IPR2017-00573

Coastal Industries v. Shower Enclosures America, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Triple Slide Assembly for Sliding Doors
  • Brief Description: The ’944 patent relates to a slide assembly for three sliding panels, such as those used for shower doors. The purported novelty is directed to features that allow track members to remain aligned with a header when rail members are adjusted, and configurations where track members are recessed into the door panels themselves to create a more compact, interlocking assembly.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3, 5, 7-9, 11-13, 17-22, and 25-26 under 35 U.S.C. §102

  • Prior Art Relied Upon: Van Weelden (Patent 4,633,614).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Van Weelden, a reference not considered during prosecution, teaches every element of the challenged claims. Van Weelden was asserted to disclose an “Adjustable Tub Enclosure and Shower Stall Doors” assembly that includes both key features later identified as novel during the prosecution of the ’944 patent. Specifically, Petitioner contended that Van Weelden teaches an adjustment mechanism (using an angled elongate slot) to compensate for out-of-plumb walls while maintaining alignment, as well as a configuration where track members are recessed into the door panels.
    • Key Aspects: The core of this argument is that a single prior art reference fully anticipates the claims, including the very features that were the basis for the patent's allowance. Petitioner noted that Van Weelden was assigned to a predecessor of Sterling Industries, a major manufacturer of similar shower doors, underscoring its relevance in the field.

Ground 2: Obviousness of Claims 1-11 and 19-21 under 35 U.S.C. §103

  • Prior Art Relied Upon: Comeau (Patent 6,892,783) and Sterling (Installation Guide 5700 Series Finesse™ Tri-Panel Bath and Shower Doors).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Comeau discloses a base multi-panel system with nested tracks designed to be narrower than conventional systems but lacks a specific mechanism for adjusting the panels to align with out-of-plumb walls. Sterling, an installation guide for a commercial three-panel shower door, was argued to supply this missing element by teaching a well-known adjustment means using angled, elongated slots in roller brackets to allow for fine alignment of the panels.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Sterling's established alignment method with Comeau's nested track system to solve the common and foreseeable problem of installing shower doors in imperfectly plumb openings. Petitioner argued this combination would predictably result in a functionally improved, space-efficient, and easily installable sliding door assembly.
    • Expectation of Success: A POSITA would have a high expectation of success because the combination involves applying a conventional adjustment solution to a known type of sliding door system to achieve a predictable improvement in installability and function.

Ground 3: Obviousness of Claims 12-16 and 22-24 under 35 U.S.C. §103

  • Prior Art Relied Upon: Comeau (Patent 6,892,783) and Jang (EU App. Pub. No. EP 0 985 793 A2).

  • Core Argument for this Ground:

    • Prior Art Mapping: As in the previous ground, Comeau was asserted to provide the basic multi-panel track system. Petitioner argued that Jang, also not considered during prosecution, teaches the second key feature of the '944 Patent: a sliding door system where track members (guide grooves) are recessed directly into sliding bars (rails) that form the upper part of the door panels.
    • Motivation to Combine: A POSITA seeking a more integrated, streamlined, and compact design would be motivated to incorporate Jang's recessed track configuration into Comeau's multi-panel system. This would allow the panels to interlock and slide relative to one another without requiring a separate, bulkier track structure, thereby achieving one of the '944 Patent's primary purported advantages.
    • Expectation of Success: Success would be expected because both references are in the analogous art of sliding door assemblies, and combining a recessed track with a multi-panel system is a straightforward design choice for achieving a more compact and elegant product.

  • Additional Grounds: Petitioner asserted additional obviousness challenges over Van Weelden in view of Sterling (Ground 3) and over Van Weelden in view of Jang and Sterling (Ground 5), relying on similar rationales to combine known features for adjustability, interlocking, and recessed configurations.

4. Key Claim Construction Positions

  • "wherein said first and second track members remain aligned with the header when the alignment of said first or said second rail members is adjusted": Petitioner argued that under the broadest reasonable interpretation, this phrase means an adjustment can be made to the rail members (e.g., for out-of-plumb walls) without changing the relative positions and orientations of the track members in relation to the header. This construction is central to arguing that prior art with simple adjustment slots (like Sterling) or inherent alignment properties (like Van Weelden) meets the limitation.
  • "wherein said first and second track members are recessed in said first and said second door panels": Petitioner proposed this term means the track (a constituent piece with a groove serving as a guide) is set back into a plane of a surface of a door panel (or a rail member included as part of a panel). This broad interpretation was asserted to allow prior art like Van Weelden (where tracks are recessed in rails) and Jang (where grooves are formed in rails) to meet the limitation, countering a potentially narrower interpretation based on specific embodiments in the '944 Patent.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-26 of Patent 7,174,944 as unpatentable.