PTAB

IPR2019-00078

InVue Security Products, Inc. v. Mobile Tech, Inc.

Title: Cable Management Apparatus for Mounting Electronic Devices
Brief Description: The ’140 patent describes a security display system for retail environments, comprising a base, a mounting member ("puck") to hold an electronic device, and a retractable tether. The patent asserts as its improvement a system where the tether lacks electrical conductors. Instead, the puck is charged via electrical contacts only when resting on the base, and security alarm signals are transmitted from the puck to the base either wirelessly or through a fiber optic tether.

Prior Art Relied Upon: Logokett (WO 2011/045058).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Logokett, which predates the ’140 patent, discloses nearly all key features of the challenged claims. Logokett teaches a retail security device with a base unit, a puck ("sensor unit 4"), and a retractable fiber optic tether. Crucially, Logokett’s puck is powered via electrical contacts when it rests on the base, and it contains a rechargeable battery ("charge store 10") to operate when lifted. The fiber optic tether transmits optical security signals, directly teaching the core elements of independent claims reciting this feature.
- Motivation to Combine (for §103 grounds): For limitations not explicitly disclosed, such as the multi-orientation docking feature of claim 19, Petitioner argued it would have been obvious to modify Logokett. A POSITA would have been motivated to incorporate known designs for multi-position charging (e.g., using concentric ring contacts) to enhance usability for various device orientations (portrait/landscape), a common requirement in retail displays.
- Expectation of Success: A POSITA would have a high expectation of success in making such modifications, as multi-orientation charging was a known and solved problem using well-understood electrical contact arrangements.

Prior Art Relied Upon: Deconinck (Patent 7,327,276) in combination with general knowledge of electrical contacts and fiber optic tethers as taught by references like Chatterjee (Application # 2010/0081473) and Davey (Patent 4,370,020).
Core Argument for this Ground:
- Prior Art Mapping: Deconinck discloses a security display with a base, a puck ("housing 30"), a rechargeable battery, and wireless transmission of security signals. However, Deconinck teaches charging the puck via wireless induction. Petitioner argued that substituting Deconinck's induction coils with conventional, more reliable, and less expensive electrical contacts was an obvious design choice for a POSITA.
- Motivation to Combine: A POSITA would combine Deconinck with the knowledge of electrical contacts to achieve a more robust and cost-effective charging solution, which was a finite and predictable solution for power transfer. Furthermore, a POSITA would have been motivated to replace Deconinck’s disclosed mechanical tether with a well-known fiber optic tether to gain the known benefits of improved security and durability against wear, as taught by numerous prior art references.
- Expectation of Success: The interchangeability of wireless induction and direct electrical contacts for charging was well-established. A POSITA would have reasonably expected that substituting one for the other, or swapping a mechanical tether for a fiber optic one, would work as intended.

Prior Art Relied Upon: The Video (MTI's 2009 Virtual Store Tour Video Publication) in combination with general knowledge of fiber optic tethers.
Core Argument for this Ground:
- Prior Art Mapping: The Video, a public disclosure by the Patent Owner’s predecessor, shows the "Freedom LP3" product. This product includes a base, a puck, a conductor-less mechanical retractor, and charging via electrical contacts when the puck is docked. The puck also communicates wirelessly with the base to trigger alarms. This system teaches all major elements of the challenged claims except for the use of a fiber optic tether.
- Motivation to Combine: Petitioner argued that a POSITA, starting with the LP3 system shown in the Video, would have been motivated to replace the mechanical tether with a fiber optic tether. This modification would provide a known, alternative method for transmitting security signals with recognized advantages in terms of preventing wear and being immune to electrical interference.
- Expectation of Success: Given that fiber optic tethers were a known and interchangeable option for security systems, a POSITA would have had a clear expectation of success in integrating one into the otherwise complete system shown in the Video.

"means for electrically coupling the electronic device to the mounting member" (claims 12, 20): Petitioner argued this means-plus-function term corresponds to the structures disclosed in the specification, namely an "adaptor cable that electrically couples the hand-held to a power fitting on the puck" or a "secondary security sensor cable."
"power storage device means" (e.g., claim 13): Petitioner proposed this term should be construed according to the specification as either "a battery" or "a large capacitor."
"electronic control board" (e.g., claim 17): Petitioner argued for a broad construction to mean "components and/or circuits for providing power and/or security-related functions in the puck assembly."
"modular retractable tether assembly" (claim 37): Petitioner contended this term means "a retractable tether assembly that can be removed and replaced," based on its description in the specification.

Contested Priority Dates: Petitioner contended that claims 19-24, 37, and 51 were not entitled to the patent’s earliest priority date, arguing that the subject matter of these claims (e.g., multi-orientation docking, modular tethers) was first introduced in later-filed continuation-in-part applications in 2013. This argument, if successful, would allow art published between the original 2010 filing and the 2013 filings (such as MTI's own 2010 product manual) to be used as prior art against those specific claims.

Petitioner requests institution of an inter partes review and cancellation of claims 1-25, 27-37, 51, 68-71, and 93-96 of Patent 9,786,140 as unpatentable.