PTAB

IPR2017-00802

Broad Ocean Technologies Inc v. Regal BEloit America Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Snap-Fit Blower Housing Assembly and Seal Method
  • Brief Description: The ’476 patent discloses a releasably locking blower housing assembly, primarily for furnace blowers. The invention uses a snap-fit mechanism where a ridge on the housing body, featuring a radially extending apex, matingly engages a corresponding channel on the housing cover to allow for repeated assembly and disassembly.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 6 & 8 are anticipated under 35 U.S.C. §102 and/or obvious under 35 U.S.C. §103 over the '840 patent.

  • Prior Art Relied Upon: '840 patent (Canadian Patent No. 2195840).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the '840 patent, which was not considered during original prosecution, discloses every element of these claims. Both the '476 patent and the '840 patent address the same problem of creating a releasable, snap-fit connection for HVAC housings to facilitate repair and maintenance. Petitioner asserted that the '840 patent’s "rabbet connection" is structurally and functionally identical to the claimed invention. The '840 patent’s housing body (bottom shell) was shown to have a "groove strip" (the claimed "ridge") with a "flank" (the claimed "apex") that extends radially outward. This structure matingly engages with a corresponding channel in the housing cover (top shell). Petitioner contended this disclosure anticipates independent claims 1 and 6. Further, the '840 patent was argued to teach the "channel" and "sloping section" limitations of dependent claims 2 and 3. For method claim 8, Petitioner argued that the '840 patent inherently teaches the steps of providing the components, aligning them, and applying pressure to cause the snap-fit engagement. The obviousness argument was presented as a fallback, stating that at a minimum, the '840 patent’s disclosure would have rendered these claims obvious to a person of ordinary skill in the art (POSITA).

Ground 2: Claims 4-5, 7 & 9-11 are obvious over the '840 patent in view of the '517 patent.

  • Prior Art Relied Upon: '840 patent (Canadian Patent No. 2195840) and '517 patent (4,865,517).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed the remaining dependent claims, which add common mechanical features. Petitioner asserted that the '840 patent provides the basic releasably locking blower housing, as established in Ground 1. The '517 patent, which relates to a "Blower With Clam Shell Housing," was cited to supply the additional known elements. Specifically, the '517 patent was argued to expressly teach:
      • An "air cavity" formed between the tongue and groove when the parts are joined, as required by claim 4.
      • A "gasket" situated within the channel to improve sealing, as recited in claims 5, 7, 9, and 11.
      • An alignment mechanism using "guide pins" and corresponding "pin holes," as required by method claim 10.
    • Motivation to Combine: Petitioner argued a POSITA would combine these references to improve the performance of the basic housing disclosed in the '840 patent. Both references are in the same field of furnace blower housings and address the common goal of achieving a secure, yet serviceable, seal. A POSITA seeking to improve the seal and ease of assembly of the '840 housing would have been motivated to incorporate well-known features like gaskets and guide pins, which were explicitly taught for that exact purpose in the '517 patent. Petitioner also noted that the USPTO, during original prosecution, had already found these same features from the '517 patent to be obvious additions to a different primary reference.
    • Expectation of Success: Petitioner contended there would have been a high expectation of success. The combination involved applying conventional, simple mechanical components (gaskets, alignment pins, air gaps) for their known functions in a predictable manner. Since the '517 patent demonstrates the successful use of these features in a nearly identical application, a POSITA would have reasonably expected them to function as intended when incorporated into the '840 patent's housing design.

4. Key Claim Construction Positions

  • "apex": Petitioner proposed this term be construed as "a tip or edge formed where two surfaces meet." This construction was based on the plain and ordinary meaning and the patent's specification. It was critical to Petitioner's argument that the structure disclosed in the '840 patent (the "flank" of the "groove strip") met this limitation, contrary to arguments the patent owner made during prosecution to distinguish over other prior art.
  • "matingly engage": Petitioner proposed this term means "to join and releasably fit parts together." This construction emphasized the "releasable" and "snap-fit" nature of the connection, which Petitioner argued was a key feature of the invention consistently described in the specification and was the explicit purpose taught in the '840 patent.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-11 of Patent 5,954,476 as unpatentable.