PTAB

IPR2017-00846

Plastic Development Group LLC v. MaxChief Investments Ltd

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Collapsible Table
  • Brief Description: The ’644 patent describes a collapsible table with a molded plastic tabletop. The design features folding leg assemblies that are supported by a brace structure and pivot into channels formed on the underside of the tabletop for storage.

3. Grounds for Unpatentability

Ground 1: Obviousness over Simpson in view of Stanford - Claims 1-6, 9-11, 14-18, and 22-24 are obvious over Simpson, either alone or in view of Stanford.

  • Prior Art Relied Upon: Simpson (Patent 6,371,034) and Stanford (Patent 6,431,092).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Simpson, which teaches a "Folding Table," disclosed nearly all elements of the challenged claims. Specifically, Simpson’s tabletop includes support plates that form opposing channels for receiving pivot shafts (the claimed "pivot bars"). Simpson further disclosed frame members ("rigid rails"), pivotable leg assemblies, and "strut arrangements" that function as the claimed support assemblies, complete with brace structures and support bars for locking the legs in a use position. For limitations in independent claim 1 regarding the pivotal attachment of leg assemblies to the frame, Simpson taught using "mounting sockets."
    • Motivation to Combine (for §103 grounds): Petitioner contended that to the extent Simpson's use of "mounting sockets" differed from the direct pivotal attachment claimed, a person of ordinary skill in the art (POSA) would have been motivated to modify Simpson's design based on the teachings of Stanford. Stanford explicitly criticized such intermediate attachment hardware as being "heavier, more costly, more difficult to install" and taught a more direct pivotal attachment of leg assemblies to the table frame. A POSA would therefore combine Stanford’s streamlined attachment method with Simpson’s overall table design to achieve a lighter, cheaper, and more easily manufactured product.
    • Expectation of Success (for §103 grounds): A POSA would have a high expectation of success in replacing Simpson's mounting sockets with the direct pivotal connection taught by Stanford, as it involved substituting one known mechanical pivot mechanism for another to achieve a predictable improvement in cost and efficiency.
    • Key Aspects: For dependent claims requiring the pivot bars to be secured by screws, Petitioner argued a POSA would find it obvious to use screws for additional securement, a common fastening technique identified in Stanford for other table components.

Ground 2: Obviousness over Stanford in view of POSA General Knowledge - Claims 1-6, 9-11, 14-18, and 22-24 are obvious over Stanford in view of the general knowledge of a POSA.

  • Prior Art Relied Upon: Stanford (Patent 6,431,092).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stanford, when its own disclosed embodiments are combined as the reference suggests, teaches all limitations of the challenged claims. Stanford’s first embodiment disclosed a table with mounting members having grooves that form a channel to retain a cross-brace member (the "pivot bar"). Stanford’s second embodiment disclosed a table with two separate cross-brace members. Petitioner asserted that all other key structural elements—including the tabletop, frame members, pivotally attached leg assemblies, and Y-shaped pivotal support braces (the claimed "support assemblies")—were disclosed in Stanford's second embodiment.
    • Motivation to Combine (for §103 grounds): Petitioner highlighted that Stanford provided an explicit motivation to combine the features of its two embodiments. Stanford stated that structural features from the first embodiment, such as the mounting members, "may be incorporated into the alternative design of the utility table [the second embodiment], if desired." A POSA, seeking to securely retain the two cross-braces of the second embodiment, would have been directly motivated by Stanford's own text to add the channel-forming mounting members from the first embodiment, thereby arriving at the claimed configuration of two opposing channels for two pivot bars.
    • Expectation of Success (for §103 grounds): A POSA would have reasonably expected success in this combination because it involved applying a disclosed retaining feature from one embodiment to analogous components in a second embodiment from the same patent, a straightforward integration of compatible parts to perform their known function.

4. Key Claim Construction Positions

  • Petitioner argued that two limitations in claim 14 contain self-evident typographical errors that render the claim unworkable as written and inconsistent with the specification and all other claims.
    • The phrase "the second end of the first support bar pivotally attached to the first pivot bar" should be construed to mean "the first end of the first support bar pivotally attached to the first pivot bar."
    • Similarly, "the second end of the second support bar pivotally attached to the second pivot bar" should be construed to mean "the first end of the second support bar pivotally attached to the second pivot bar."
  • Petitioner contended that this correction is necessary because the specification and figures consistently show the first end of the support bar attaching to the pivot bar and the second end attaching to the brace structure.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-6, 9-11, 14-18, and 22-24 of the ’644 patent as unpatentable.