PTAB

IPR2018-01793

Nortek Security & Control LLC v. Chamberlain Group Inc

Key Events

Petition

petition

Case #: IPR2018-01793
Patent #: 6,741,052
Filed: September 28, 2018
Petitioner(s): Nortek Security & Control LLC, GTO Access Systems, LLC, and Nortek, Inc.
Patent Owner(s): The Chamberlain Group, Inc.
Challenged Claims: 1-35

Title: Movable Barrier Operator with User-Adjustable Performance Limits
Brief Description: The ’052 patent discloses a control system for movable barriers, such as garage doors, that automatically determines performance limits (e.g., force thresholds) during a "learning mode" of operation. The system then allows a user to perform a subsequent, non-automatic manual adjustment to these automatically determined limits.

Prior Art Relied Upon: Duhame (Patent 5,218,282) and Fitzgibbon-2000 (Patent 6,107,765).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Duhame taught a control system for a motorized barrier that automatically determines adaptive torque (force) limits and allows for manual user modification of those limits via potentiometers. This system addresses the core limitations of independent claims 1, 22, and 27. Petitioner asserted that Fitzgibbon-2000, whose inventor is the same as the ’052 patent’s inventor, explicitly taught a dedicated "learn mode" where force and travel limits are automatically set during an initial installation cycle.
- Motivation to Combine: A POSITA would combine Fitzgibbon-2000’s efficient "learn mode" with Duhame’s system to improve the convenience and accuracy of the initial installation. Petitioner contended that Duhame’s method of setting limits was an iterative, multi-step process, whereas Fitzgibbon-2000’s learn mode offered a more streamlined "fast and accurate" single-cycle setup, addressing a known problem in the field.
- Expectation of Success: Petitioner asserted a high expectation of success because both references were in the same technical field of garage door openers, their systems were highly compatible, and implementing a software-based learning mode was a trivial modification for a POSITA.

Prior Art Relied Upon: Duhame (Patent 5,218,282), Fitzgibbon-2000 (Patent 6,107,765), and Schindler (Patent 4,638,433).
Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the combination in Ground 1 to address claims requiring the user’s manual force adjustment to be limited to a specific range (e.g., less than 25% of the total potential applicable force). Petitioner argued that Schindler explicitly taught limiting user adjustments for safety reasons, disclosing that setting force limits too high creates a "dangerous condition." Schindler suggested setting limits only "slightly as, for example, 10% above these required forces."
- Motivation to Combine: A POSITA would be motivated to add Schindler's safety limitation to the system of Ground 1 to prevent misuse. The desire to avoid unsafe conditions, particularly where a user could set dangerously high force thresholds, would have provided a strong reason to limit the range of manual adjustment.
- Expectation of Success: Success would be expected, as implementing a limit on a user input range, whether electronically or mechanically, was a simple and well-understood design choice aimed at enhancing product safety.

Prior Art Relied Upon: Leivenzon (WO 2000/072436).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Leivenzon, as a single reference, disclosed all the allegedly novel features of the ’052 patent. Leivenzon taught a garage door opener system that used an initialization or "set up facility" (a first mode of operation) to automatically learn and calculate "safety obstruction parameters" (force thresholds) by running the door through a full open-close cycle. Leivenzon further disclosed dividing the door’s travel into multiple segments, each with its own threshold. Crucially, Leivenzon also explicitly taught a means for a user to manually modify these automatically determined resistance values (a second mode of operation).
- Motivation to Combine: This is a single-reference ground. Petitioner contended that Leivenzon alone taught the combination of automatic force calibration in a learning mode with subsequent manual user adjustment, rendering the challenged claims obvious.

Processor (Claims 1, 8, 14, 18-19): Petitioner proposed this term be construed to include any processor performing the claimed functions. If treated as a means-plus-function term, the functions included automatically determining force thresholds during a first "learning" mode for use in a second "normal" mode of operation.
Learning means (Claims 14-16): The required function was defined as "sensing the at least some forces acting upon the movable barrier when the movable barrier moves during a learning mode." The corresponding structure was identified as "code for receiving input from sensors regarding the forces acting upon the motor."
Control means (Claims 22-26): The required function included operating in two modes: (1) a first mode for automatically measuring forces to establish a maximum force threshold, and (2) a second mode for modifying and using that threshold in response to user input. The corresponding structure was a general "programmable platform."

Petitioner requested the institution of an inter partes review and the cancellation of claims 1-35 of the ’052 patent as unpatentable.