PTAB

IPR2020-00387

VeRSA Products v. Varidesk LLC

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1. Case Identification

2. Patent Overview

  • Title: Electrically-Lifted Computer Desk
  • Brief Description: The ’336 patent discloses an adjustable-height desktop unit designed to be placed on an existing work surface. The unit uses a scissor-lift mechanism, powered by an electric motor and a screw-type drive, to raise and lower a top face plate relative to a bottom plate.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Laudadio - Claims 1-18 are unpatentable under 35 U.S.C. §§102 or 103 over Laudadio.

  • Prior Art Relied Upon: Laudadio (Patent 10,413,055).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Laudadio, which was not considered during prosecution, teaches every element of the challenged claims. Laudadio discloses a motorized desktop stand with a scissor-lift mechanism, a bottom tray ("bottom plate"), an upper tray ("face plate"), side-support members, and a transverse link (reinforcer tube). Petitioner asserted that while Laudadio expressly discloses a "linear actuator," its specification states that various types of linear actuators could be used, which inherently includes the screw-rod drive recited in claim 1. Petitioner also mapped the limitations of all dependent claims (2-18) to specific components and descriptions within Laudadio.
    • Motivation to Combine (for §103 grounds): As an alternative to anticipation, Petitioner argued that if Laudadio were found not to expressly disclose a screw rod, it would have been obvious to a Person of Ordinary Skill in the Art (POSITA) to implement one. Both linear actuators and screw-rod drives were well-known mechanisms for achieving linear motion. A POSITA would combine the known screw-rod drive with Laudadio's system as a simple design choice to achieve the same lifting result, with a potential motivation being cost differences between actuator types.
    • Expectation of Success: A POSITA would have a high expectation of success in substituting a well-known screw-rod drive for the linear actuator in Laudadio's mechanical lift system, as it is a predictable substitution of equivalent components.

Ground 2: Anticipation over Wynn - Claims 1-16 are unpatentable under §102 over Wynn.

  • Prior Art Relied Upon: Wynn (Patent 3,928,946).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wynn, which was considered during prosecution, anticipates claims 1-16. During prosecution, the Patent Owner overcame a rejection over Wynn by arguing that the examiner improperly identified a single component (H-1) as both the claimed "transverse link" and the "nut sliding rod block." Petitioner contended this argument was fatally flawed because a different component in Wynn, transverse shaft N, clearly teaches the "transverse link." With shaft N correctly identified as the transverse link, Petitioner asserted that Wynn’s disclosure meets every limitation of claim 1, including the nut sliding rod block (H-1) being coupled to the transverse link (N) via a side-support piece. The petition then maps the limitations of dependent claims 2-16 to elements within Wynn.

Ground 3: Obviousness over Laudadio in view of Chouinard or Wynn - Claims 1-18 are obvious over Laudadio in view of either Chouinard or Wynn.

  • Prior Art Relied Upon: Laudadio (Patent 10,413,055), Chouinard (Patent 7,677,518), and Wynn (Patent 3,928,946).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Laudadio teaches every element of claim 1 except for an explicit "screw rod," instead disclosing a generic "linear actuator" and suggesting other known types could be used. Both Chouinard and Wynn disclose adjustable-height desktops that are actuated by explicit screw-rod drive mechanisms. The combination of Laudadio with either Chouinard or Wynn supplies all limitations of claim 1.
    • Motivation to Combine: A POSITA would combine the screw-rod drive taught by Chouinard or Wynn with the lifting structure of Laudadio to create the claimed invention. The motivation would be to use a conventional, reliable, and commercially available actuator to power the scissor-lift mechanism described in Laudadio. This combination would allow a designer to retain the structural benefits of Laudadio's system, such as the stabilizing transverse link, while implementing a well-known drive mechanism.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involves the straightforward substitution of one known mechanical actuator for another within a predictable lifting system to achieve an expected result.
  • Additional Grounds: Petitioner asserted additional challenges, including that claims 1-4, 9-12, and 17 are anticipated by or obvious over Faitel (Application # 2003/0047388), and that claims 1-18 are obvious over Chouinard in view of Laudadio or Wynn.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’336 patent as unpatentable.