PTAB

IPR2019-01184

KAIdi LLC v. LiMOSs US LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Linear Actuator and Assembly Method
  • Brief Description: The ’717 patent discloses a linear actuator assembly primarily for adjustable furniture. The system uses an electric drive motor to rotate a threaded spindle housed within a rigid arm, causing a pusher block coupled to a spindle nut to slide along the arm and actuate an attached linkage.

3. Grounds for Unpatentability

Ground 1: Anticipation over ’885 Publication - Claims 1, 5-8, 10-12, 15, and 18-20 are anticipated under 35 U.S.C. §102 by the ’885 Publication.

  • Prior Art Relied Upon: Kristen (’885 Publication) (Application # 2015/0033885).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that because the ’717 patent is not entitled to its claimed priority date, the ’885 Publication—filed by the same inventor—qualifies as §102 prior art. Petitioner argued the ’885 Publication discloses an identical linear actuator and provided extensive side-by-side comparisons of figures from both documents to show a one-to-one correspondence for every element of independent claim 15. This included the rigid arm, threaded spindle, spindle nut, pusher block, a rigid arm passage through which the arm slides, and an attachment projection (clevis) for pivotally connecting a linkage. For method claim 1, Petitioner contended that the assembly steps were inherently disclosed by the publication’s description and figures showing the fully assembled structure.

Ground 2: Obviousness over ’885 Publication and Chiang - Claim 9 is obvious over the ’885 Publication in view of Chiang.

  • Prior Art Relied Upon: ’885 Publication (Application # 2015/0033885) and Chiang (Application # 2010/0186529).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground challenged dependent claim 9, which adds first and second limit switches to the base actuator of claim 1. Petitioner argued the ’885 Publication taught the base actuator, while Chiang taught the additional limitations. Specifically, Chiang discloses positioning a first limit switch (45) and a second limit switch (46) inside a protective tube (the rigid arm). A contacting portion on the actuator's nut (42) touches triggers on the switches to sense the pusher block's position and electronically disrupt power to the drive motor, thereby stopping travel at precise limits.
    • Motivation to Combine: A POSITA would combine the teachings to add a known control mechanism to the actuator of the ’885 Publication. The ’885 Publication mentioned a "control means" without providing implementation details, which would motivate a POSITA to look to references like Chiang for known methods of implementing travel-limit control to improve accuracy, positional control, and safety.
    • Expectation of Success: Integrating standard limit switches into a linear actuator was a routine and predictable modification for a skilled person.

Ground 3: Obviousness over Koch and Lipinski - Claims 1, 5-6, 8, 11-12, 15, and 18-19 are obvious under 35 U.S.C. §103 over Koch in view of Lipinski.

  • Prior Art Relied Upon: Koch (Patent 5,927,144) and Lipinski (Patent 4,512,208).

  • Core Argument for this Ground:

    • Prior Art Mapping: As an alternative position, Petitioner argued that even if the ’717 patent were entitled to priority, it would be obvious over other art. Koch was asserted to teach most claimed elements, including a linear actuator with a threaded spindle, a nut, and a pusher block (slider) that engages a rigid arm. Petitioner argued Koch did not explicitly disclose an attachment projection extending outwardly from the pusher block that defines a linkage channel. Lipinski was used to supply this feature, as it discloses a guide yoke (pusher block) with an outwardly extending projection that defines a linkage channel for pivotally connecting a linkage.
    • Motivation to Combine: A POSITA would combine the references to achieve the "improved mechanical stability" and "low-cost manufacture" explicitly sought by Koch. Lipinski provided a known, simple, and effective method for attaching a linkage to a pusher block, making it an obvious modification to the Koch design.
    • Expectation of Success: The combination involved applying a known linkage attachment technique to a known actuator design, which would have been a straightforward task for a skilled person with a high expectation of success.

  • Additional Grounds: Petitioner asserted additional grounds including anticipation of claims 1, 5-7, 10, 15, 18, and 20 over Duhame (Patent 5,588,257) and obviousness of claim 9 over the three-way combination of Koch, Lipinski, and Chiang.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Claim Invalidity: A foundational argument of the petition was that the ’717 patent is not entitled to its claimed priority dates. Petitioner contended that a break in the continuity of disclosure occurred because the parent ’432 application was substantively different from its own provisional application and failed to provide written description support for key limitations of the ’717 patent, including the "threaded spindle," "rigid arm passage," and "attachment projection." This alleged priority break was critical to Petitioner's primary ground, as it would render the inventor’s own ’885 Publication invalidating prior art under §102.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 5-12, 15, and 18-20 of Patent 10,066,717 as unpatentable.