PTAB

IPR2020-00887

One World Technologies Inc v. Chervon HK Ltd

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Gardening Tool
  • Brief Description: The ’686 patent describes a safety system for electric gardening equipment, such as a walk-behind lawnmower, that prevents activation of the motor when the handle is improperly positioned. The system uses electrical circuits to disable the motor when the handle is rotated out of a designated in-use position or when a telescopic handle is in a collapsed state for storage.

3. Grounds for Unpatentability

Ground 1: Obviousness over Reichart, Nakano, Outils, and 16 CFR 1205 - Claims 1-14 and 18-20 are obvious over the combination of these references.

  • Prior Art Relied Upon: Reichart (GB 2,386,813), Nakano (WO 2013/122266A2), Outils (FR 2,768,300), and 16 CFR 1205 (2012).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Reichart taught the base invention: a lawnmower with a rotatable and telescoping handle. Outils was cited for teaching a safety system with a cam-actuated switch that disables the motor when the handle is rotated out of its designated in-use position, addressing the rotational safety limitations. Nakano was cited for teaching a safety system that disables a motor when a telescoping handle is retracted or collapsed, addressing the sliding/telescoping safety limitations. The combination of these references was argued to disclose all elements of the independent claims.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to enhance the safety of the lawnmower disclosed in Reichart. The motivation would stem from the known dangers of lawnmowers and the desire to create a comprehensively safe product. Petitioner asserted that a POSITA would logically add Outils's rotational safety feature and Nakano's telescoping safety feature to Reichart's base design. Furthermore, 16 CFR 1205, a federal safety regulation for lawnmowers, would have motivated a POSITA to incorporate such safety interlocks to ensure regulatory compliance and reduce consumer injury risk.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these systems. The integration of known electrical switches, cam mechanisms, and position sensors into a lawnmower handle represents a predictable application of conventional technology, not an inventive leap.

Ground 2: Obviousness over Reichart, Nakano, Outils, 16 CFR 1205, and Matsunaga - Claims 15-17 are obvious over the combination of these references.

  • Prior Art Relied Upon: Reichart (GB 2,386,813), Nakano (WO 2013/122266A2), Outils (FR 2,768,300), 16 CFR 1205 (2012), and Matsunaga (Patent 8,098,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1, adding Matsunaga to teach the specific limitations of claims 15-17 related to a "signal source." Petitioner argued that while the primary combination taught the overall safety system, Matsunaga taught a more refined and desirable implementation. Specifically, Matsunaga disclosed using a low-current contact switch (a "signal source") to send a control signal to a separate, high-current semiconductor switch (e.g., a FET) that directly controls power to the motor. This contrasts with running the full motor current through the user-operated switch.
    • Motivation to Combine: A POSITA would be motivated to incorporate Matsunaga's teachings into the lawnmower of the primary combination for reasons of safety, durability, and cost. Using a low-current signal path to the handle switches avoids the danger and expense associated with routing thick, high-current wiring through user-accessible components. This design allows for smaller, less expensive, and more reliable switches on the handle, which would be a clear and obvious improvement.
    • Expectation of Success: Implementing a relay or semiconductor-based switching circuit controlled by a low-power signal was a standard, well-understood electrical engineering practice. A POSITA would have found it entirely predictable to apply Matsunaga's circuit design to control the motor in the combined Reichart/Nakano/Outils device.

4. Key Claim Construction Positions

  • "Power Supply Circuit" (Claims 2, 5, 9-10, 12, 15, 19-20): Petitioner argued this term should be construed as "the electrical path between an electric power source and the motor taken by (high-power) current that drives the motor." This construction was proposed to distinguish between components directly connected in the high-power path versus control components that send a signal to that circuit, a distinction Petitioner contended was critical to understanding the prior art's teachings.
  • "Locks" and "Unlocks" (Claims 1, 8, 11, 18): Petitioner argued these terms should be construed as "electrically disabling" and "electrically enabling," respectively. As the ’686 patent disclosed no mechanical locking mechanism for the motor's operation, a POSITA would understand these terms to refer to the electrical prevention or permission of motor activation by the safety control devices.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-20 of the ’686 patent as unpatentable.