PTAB

IPR2018-01218

Mobile Tech Inc v. Sennco Solutions Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Securing, Attaching, and/or Detaching a Device to a Surface
  • Brief Description: The ’336 patent discloses a security apparatus for displaying portable electronic devices in a retail setting. The system includes a head unit that attaches to the device, a post that mounts to a fixture, and a tether cable connecting the head unit to the post, allowing for removal of the device from the post using a key.

3. Grounds for Unpatentability

Ground 1: Obviousness over a Single Security System Reference - Claims 1 and 3-8 are obvious over Seabrook.

  • Prior Art Relied Upon: Seabrook (WO 2012/069816).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seabrook, which discloses an "electronic device display and security unit," teaches all elements of the challenged claims. Seabrook's "display module 39" was identified as the claimed head unit, its "collar 11" as the claimed spring, and its "key 12" as the claimed key. The method steps of connecting the head unit to a post via a connector, and using a key to remove the cable from the head unit, were alleged to be fully disclosed. Petitioner asserted Seabrook’s elastic "collar 11," which has a longitudinal split enabling compression, functions as a spring to removably secure the tether's connector within the head unit.
    • Motivation to Combine (for §103 grounds): While this ground is based on a single reference, Petitioner addressed a potential distinction where Seabrook’s post mounts partially through a display fixture rather than entirely on top of it. Petitioner argued a person of ordinary skill in the art (POSITA) would have found it an obvious design choice to modify the Seabrook post to mount entirely on the fixture surface to simplify installation, as this was a common configuration for such security systems.
    • Expectation of Success (for §1o3 grounds): A POSITA would have a high expectation of success in making this minor modification, as it involved a well-known alternative mounting configuration that required only routine adaptation.

Ground 2: Obviousness by Adding Wireless Alarm Capability - Claims 9-10 and 12-13 are obvious over Seabrook in view of Deconinck.

  • Prior Art Relied Upon: Seabrook (WO 2012/069816) and Deconinck (Patent 7,327,276).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Seabrook reference by adding Deconinck to teach the limitations of a printed circuit board (PCB) with wireless alarm communication. Deconinck disclosed a security system with a sensor (plunger switch "37") that wirelessly transmits an alarm signal if a handheld device is removed from its housing in an unauthorized manner. Petitioner argued that Seabrook’s head unit already included a PCB ("circuit 6") and that adding Deconinck’s plunger switch and wireless transmitter to it would be a straightforward modification.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Deconinck’s wireless alarm with Seabrook’s mechanical security system to gain the significant advantage of remote monitoring. This would enable store personnel to be immediately alerted to a theft attempt from anywhere in the store, improving upon a purely mechanical system.
    • Expectation of Success (for §103 grounds): A POSITA would have a high likelihood of success in integrating a known plunger switch and wireless transmitter onto an existing PCB within a security device head unit.

Ground 3: Obviousness by Modifying the Mounting Base - Claims 14-18 and 20 are obvious over Seabrook and Deconinck in view of FOPM.

  • Prior Art Relied Upon: Seabrook (WO 2012/069816), Deconinck (Patent 7,327,276), and FOPM (Freedom ONE Product Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground further modified the proposed combination of Seabrook and Deconinck by incorporating the base design from FOPM. FOPM, a product manual for a commercial security system, disclosed a base that mounts to any flat surface using adhesive pads, eliminating the need to drill holes. The FOPM base includes a post, a crown with a recession to receive the head unit ("puck"), and a retractable reel ("CarbonTether housing") inside the post.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to replace Seabrook’s post with FOPM’s base to create a security system that is easier and faster to install without permanently altering display surfaces. This modification would make the system more versatile, particularly for temporary or seasonal displays where drilling holes is impractical. Both Seabrook and FOPM were in the same field and solved similar problems of securing retail merchandise.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in combining these elements, as it involved substituting one type of mounting base for another known, advantageous type and making minor, predictable adaptations to mate the components.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations using Rabinowitz (Patent 7,667,601) to teach power cord monitoring for an alarm, and Fawcett (Application # 2011/0047844) as an alternative to FOPM for teaching a surface-mounted post design.

4. Key Claim Construction Positions

  • "spring": Petitioner argued this term should be construed as "an elastic component which stores mechanical energy and exerts a force when deformed." This construction was central to the argument that Seabrook’s "collar 11," an elastic component with a longitudinal split that deforms to release a connector, met the claim limitation for a spring, even if it is at rest when holding the connector. Petitioner contended that Patent Owner’s potential position—that a structure is only a spring when stressed—was unworkable and previously rejected by the Board.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1 and 3-20 of the ’336 patent as unpatentable.