PTAB

IPR2018-00085

PRECoR Inc v. Green Fitness Equipment Co LLC

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1. Case Identification

2. Patent Overview

  • Title: Current Monitoring and Display for Electrical Equipment
  • Brief Description: The ’553 patent discloses a system and method to monitor current drawn by an electrical device and display the current range using multi-colored Light Emitting Diodes (LEDs). The invention is described as a power cord with an integrated current monitor that includes a latching mechanism to retain the displayed color after the equipment stops being used.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-9, 11-14, and 16-17 are obvious over Yewell in view of Wang.

  • Prior Art Relied Upon: Yewell (Patent 5,900,804) and Wang (Patent 7,397,267).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yewell, an indicating power cord system, discloses the core features of independent claim 1, including obtaining current from a power source, comparing it against multiple thresholds, and activating different colored LEDs based on the comparison. However, Yewell lacks a latching mechanism to retain the LED display after use. Petitioner asserted that Wang remedies this deficiency by teaching a power monitoring device with a timer circuit that functions as a latching mechanism, retaining an LED indicator's state to alert an operator to a transient power fault, even after the event passes.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Yewell and Wang because both are in the same field of power monitoring. Wang expressly describes an improvement for "typical" detecting circuits (like Yewell's) by adding a latching mechanism to solve the problem of operators overlooking transient faults. This is the same rationale provided in the ’553 patent for including a latch.
    • Expectation of Success: A POSA would have a reasonable expectation of success in combining Wang’s digital timer and latching circuit with Yewell’s power cord monitor. The integration was presented as a predictable application of known components to achieve the desired function of retaining a fault indication.

Ground 2: Claims 1-3, 5-10, 12-15, and 17 are anticipated by Digitrip.

  • Prior Art Relied Upon: Digitrip (Eaton-Cutler-Hammer Owner's Manual, EX1004).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Digitrip, a user manual for a sophisticated circuit breaker subsystem, anticipates nearly all challenged claims. Digitrip was argued to disclose a method of (1) obtaining current from power sensors, (2) comparing the current against multiple, user-programmable thresholds (e.g., Long Delay, Short Delay, Instantaneous), (3) activating different colored LEDs (green for status, yellow for alarm, red for trip) based on these comparisons, and (4) using a latch chip and battery to retain the red trip LED's color after the equipment trips and stops drawing current. Dependent claims reciting user-adjustability and test components were also argued to be expressly disclosed in Digitrip's programming and testing functions.
    • Key Aspects: Unlike the obviousness grounds, this ground asserted that a single prior art reference—a publicly available user manual for a commercial product sold since 2004—disclosed every element of the claimed invention, including the core concepts of multi-threshold comparison, multi-color indication, and latching.

Ground 3: Claims 2, 10, and 15 are obvious over Yewell in view of Wang and in further view of Simpson.

  • Prior Art Relied Upon: Yewell (Patent 5,900,804), Wang (Patent 7,397,267), and Simpson (Patent 6,049,143).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the Yewell and Wang combination from Ground 1 to specifically address the "user-adjustable" threshold limitation in dependent claims 2, 10, and 15. Petitioner argued that while the Yewell/Wang combination taught the basic system, it did not explicitly disclose user-adjustable thresholds. Simpson was introduced to supply this missing element, as it teaches a current monitoring apparatus with a variable resistor allowing users to manually adjust the trip level.
    • Motivation to Combine: A POSA would be motivated to add Simpson’s user-adjustability to the Yewell/Wang combination to create a more versatile and commercially desirable product. Simpson provides the explicit rationale of allowing the device to be adapted for a wider range of electrical equipment and applications, a predictable benefit.
    • Expectation of Success: A POSA would expect success in incorporating a well-known component like a variable resistor (as taught by Simpson) into the Yewell/Wang circuit to make the current thresholds user-adjustable, as this was a standard design technique.

  • Additional Grounds: Petitioner asserted several other obviousness challenges, including combinations of Yewell and Wang with Klein (Patent 5,796,349) to add a "lubrication requirement" basis for monitoring current. It also presented multiple grounds based on Digitrip in view of other references (Lagree, Simpson, Klein) to address any perceived deficiencies in Digitrip's disclosure for certain limitations, such as multichannel switches and comparator details.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the phrase “previously deactivated one or more light emitting diodes are disabled from reactivation until the latching mechanism is reset” (claims 6 and 12).
  • Petitioner contended this phrase should be construed as introducing, for the first time, the requirement to deactivate an LED. It was argued that the independent claims only require activating LEDs, and since the first LED to activate (e.g., a green "normal" light) would have no previously deactivated LED, this limitation is new. This construction was central to its arguments for how prior art teaching the deactivation of a "normal" status light upon a "fault" condition meets this limitation.

5. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner asserted that prior art references teaching the monitoring of "power" (like Yewell) inherently teach the monitoring of "current" as required by the claims. The argument was that because the systems operate at a constant voltage (e.g., from a standard wall outlet), power is directly proportional to current (P=V×I). Therefore, a POSA would understand that measuring power levels is functionally equivalent to measuring and comparing current levels in this context.

6. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and issue a final written decision cancelling claims 1-17 of the ’553 patent as unpatentable.