PTAB

IPR2017-01859

Cordelia Lighting Inc v. Cooper Lighting LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: LED Module With On-Board Reflector-Baffle-Trim-Ring
  • Brief Description: The ’956 patent describes a light-emitting diode (LED) light module for recessed lighting fixtures. The purported invention is a mounting mechanism that allows a single module to be adjustably installed into ceiling housings of different diameters, such as five-inch and six-inch cavities, by providing mounting pads with multiple receiving holes for torsion springs.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4-6, and 8-10 are anticipated by Chou under 35 U.S.C. §102.

  • Prior Art Relied Upon: Chou (Application # 2012/0206926).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chou, which was not considered during the original prosecution, teaches every element of the challenged claims. Independent claim 1 recites a light module with a heat sink, light sources, and a plurality of mounting pads, each with a first and second receiving hole to couple the module to housings of different diameters (e.g., five-inch and six-inch) via a torsion spring. Petitioner contended Chou discloses an identical structure, showing a light module with mounting brackets having multiple receiving holes that allow torsion springs to be adjusted to install the module into recessed cans of various sizes, including 5-inch and 6-inch diameters.
    • Prior Art Mapping (cont.): Petitioner further asserted that Chou discloses the limitations of the dependent claims, including a smooth reflector region (claim 2), a driver coupled to the heat sink (claim 4), and recessed openings in the mounting pad (claims 5 and 10). For claim 6, Petitioner argued Chou discloses a mounting pad with a first radial portion and a second perpendicular surface, as well as a removably coupled mounting bracket with a planar portion.

Ground 2: Claims 1-2, 4-6, and 8-10 are obvious over Chou in view of Knoble under 35 U.S.C. §103.

  • Prior Art Relied Upon: Chou (Application # 2012/0206926) and Knoble (Patent 8,070,328).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to anticipation, focusing on the "slot" limitation recited in claim 6. Petitioner contended that while Chou discloses all other claim elements, its use of two discrete holes in its mounting bracket might be distinguished from the claimed "slot." Knoble, however, explicitly teaches the use of an "adjustment slot" in a fixture frame to allow for vertical adjustment of a downlight module relative to its mounting rails. Petitioner argued that a person of ordinary skill in the art (POSITA) would have found it obvious to modify Chou’s two-hole adjustment mechanism by replacing the two holes with a single slot as taught by Knoble to achieve the same adjustability. The arguments for all other challenged claims relied on the disclosures in Chou as detailed in Ground 1.
    • Motivation to Combine: A POSITA would combine Chou and Knoble to improve the ease of adjustment. Chou's design requires removing a screw from one hole and re-inserting it into another to change the mounting position for different housing sizes. Knoble teaches that using a slot simplifies this process, allowing a user to merely loosen a screw, slide the bracket to the new position, and re-tighten it. This is a simple substitution of one known element (multiple holes) for a known equivalent (a slot) to obtain the predictable and known benefit of more convenient adjustment without full disassembly.
    • Expectation of Success: A POSITA would have had a high expectation of success in making this modification. Both Chou and Knoble are in the same field of recessed LED downlights and address the common problem of fitting a module into a housing. Using a slot for mechanical adjustment is a fundamental and well-understood design choice, and its application to Chou’s mounting bracket would yield entirely predictable results.

4. Key Claim Construction Positions

  • The Petitioner requested that claim terms be given their broadest reasonable construction. It noted that in parallel litigation, it would accept certain constructions proposed by the Patent Owner, including:
    • “coupled”: "directly or indirectly mounted"
    • “reflector”: "any material capable of being made reflective, for example, a material capable of having white reflective paint adhered to its surface"

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-2, 4-6, and 8-10 of the ’956 patent as unpatentable.