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 discloses a slide assembly for three sliding panels, such as those used for shower doors. The purported novelty relates to an adjustable rail system where track members remain aligned with a header during adjustment and an alternative configuration where track members are recessed into the door panels.

3. Grounds for Unpatentability

Ground 1: Obviousness over Comeau and Sterling - Claims 1-11 and 19-21 are obvious over Comeau in view of Sterling.

  • 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 argued that Comeau taught a multi-panel track system with nested tracks designed to create a narrower assembly, disclosing most elements of the challenged claims. Sterling, an installation guide for a commercial three-panel shower door, taught the specific missing element: an adjustment mechanism using elongated, angled slots in the roller brackets to allow for panel alignment, particularly to compensate for out-of-plumb walls.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Comeau's space-efficient nested track design with Sterling's well-known and practical adjustment feature. The motivation would be to create a predictable and improved shower door assembly that is both compact and easily adjustable during installation, a common problem in the field.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success, as incorporating Sterling’s simple mechanical adjustment mechanism into Comeau's track system involved applying known design principles to achieve the predictable result of an adjustable, nested-track door assembly.

Ground 2: Anticipation by Van Weelden - Claims 1-3, 5, 7-9, 11-13, 17-22, and 25-26 are anticipated by Van Weelden.

  • Prior Art Relied Upon: Van Weelden (Patent 4,633,614).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Van Weelden, a single prior art reference not considered during the original prosecution, disclosed every element of the challenged claims. Van Weelden described a three-panel "Adjustable Tub Enclosure and Shower Stall Doors" that included both the adjustability features (using angled slots for out-of-plumb compensation) and a panel/door recessed track member configuration, which were the two key features cited as reasons for allowance of the ’944 patent. The reference taught glides or rollers mounted on transverse tracks within a header, functionally equivalent to the claimed assembly.

Ground 3: Obviousness over Comeau and Jang - Claims 12-16 and 22-24 are obvious over Comeau in view of Jang.

  • 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: This ground primarily addressed the limitation "wherein said first and second track members are recessed in said first and said second door panels." Petitioner argued that Comeau provided the foundational three-panel nested track system. Jang, which also was not considered during prosecution, taught a sliding door system for bathrooms where sliding bars mounted above the door panels included guide grooves (track members) for a slider, rendering obvious the concept of recessing a track into a panel.
    • Motivation to Combine: A POSITA seeking to create a more integrated or compact version of Comeau’s assembly would have been motivated to look to analogous art like Jang. A POSITA would combine Jang's recessed track configuration with Comeau's multi-panel system to achieve a known benefit of a sleeker design, where the track is integrated directly into the rail or panel structure.
    • Expectation of Success: The combination was a straightforward application of known design elements, and a POSITA would have expected success in integrating a recessed track feature into a standard multi-panel sliding door assembly.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that all claims (1-26) are obvious over Van Weelden in view of Sterling (Ground 3), and that claims 12-18 and 22-26 are obvious over Van Weelden in view of Jang and Sterling (Ground 5). These grounds relied on similar arguments, primarily using Sterling to add features like interlock bumpers or to reinforce the obviousness of adjustability, and using Jang to reinforce the obviousness of recessed tracks.

4. Key Claim Construction Positions

  • "are recessed in": Petitioner argued for the construction "set back into a plane of a surface [onto] which it is fixed or located." This broad interpretation was crucial for arguing that prior art like Van Weelden, which showed panel-holding members set into glides (tracks), met the limitation.
  • "remain aligned with the header when the alignment of...rail members is adjusted": Petitioner proposed this means that 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. Petitioner argued this describes a standard property of such adjustment mechanisms, as taught by Sterling and Van Weelden.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-26 of the ’944 patent as unpatentable.