PTAB

IPR2020-01470

W W Mfg Co Inc v. Jager Pro Inc

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1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Animal Trapping
  • Brief Description: The ’228 patent relates to systems and methods for remotely capturing wild animals, such as feral pigs. The invention describes a trap comprising an enclosure with a remotely actuated gate, where the enclosure uses the natural ground as its floor, and a camera system allows a user to monitor the trap and trigger the gate via a remote control mechanism.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Prior Art - Claims 1-3, 13-17, and 26-27 are obvious over TB1 in view of TB2, Jeong, and optionally Vorhies.

  • Prior Art Relied Upon: TB1 (The Trapping Webpage), TB2 (The TexasBoars "How to Build a Wild Hog Trap" Presentation), Jeong (Korean Patent No. 100688243), and Vorhies (Application # 2005/0097808).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of TB1 and TB2 (the “TexasBoars Combination”) taught the fundamental physical structure of the claimed invention: a large, floorless corral trap with a guillotine-style gate for capturing wild pigs. Petitioner asserted that Jeong taught all remaining elements of the remote-control system, disclosing a camera for monitoring animals, a remote control unit with a display for an operator, and a solenoid-based mechanism to trigger a trap upon receiving a signal from the remote unit. Vorhies was cited as further evidence teaching solenoid-actuated door release mechanisms for animal traps.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the physical trap of the TexasBoars Combination with the remote monitoring and triggering system of Jeong. The motivation was to replace the simple mechanical tripwire of a conventional trap with a remote, operator-controlled electronic trigger. This substitution would grant the operator greater control over the trapping event, allowing them to wait for an entire herd of pigs to enter the enclosure, thereby increasing the trap's effectiveness and yielding predictable results.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involved the integration of known components (a corral trap, a camera, a remote control, a solenoid) for their recognized and intended purposes.

Ground 2: Obviousness over Core Prior Art in view of Silsby - Claims 4-9, 18-20, and 24-25 are obvious over the combination of Ground 1 and Silsby.

  • Prior Art Relied Upon: The combination from Ground 1, further in view of Silsby (Application # 2006/0203101).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1. Petitioner argued that Silsby taught a motion-detecting camera system that automatically transmits images to a base unit, which could be a cellular telephone or a laptop. The addition of Silsby was intended to explicitly teach limitations in dependent claims requiring a "wireless handheld device," a "cellular telephone," or a "motion sensor." Silsby also taught transmitting signals to multiple display devices, such as a phone and a laptop.
    • Motivation to Combine: A POSITA would be motivated to incorporate the teachings of Silsby to improve the trapping system by using a common, portable, and reliable device like a cellular telephone as the user interface. This would enhance the portability and ease of use of the remote monitoring and control system disclosed by Jeong.

Ground 3: Obviousness over Core Prior Art in view of Kimura - Claims 10, 11, 21, 22, and 28 are obvious over the combination of Ground 1 and Kimura.

  • Prior Art Relied Upon: The combination from Ground 1, further in view of Kimura (Japanese Application Publication No. 2004-97019).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added Kimura to the core combination from Ground 1. Petitioner contended that Kimura taught an animal trap that is remotely monitored and managed using an "Internet camera" that transmits image data to a mobile terminal (e.g., a mobile phone) via the internet. This reference was used to specifically address claim limitations requiring an "internet protocol web camera" and the transmission of signals over a "wireless internet network."
    • Motivation to Combine: A POSITA seeking to implement the remote trapping system would have been motivated to use an IP camera as taught by Kimura. This was presented as a common and obvious technological choice to achieve the desired goal of remote monitoring and management over a widely available network like the internet.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 12 and 23. This ground relied on a combination of all previously cited references (TB1, TB2, Jeong, Vorhies, Kimura, and Silsby) to teach a method where the display device is a computer, arguing that the teachings of Jeong, Silsby, and Kimura all disclose or suggest computer-based remote control units.

4. Key Claim Construction Positions

  • Petitioner argued that the term "telephone controller" required construction. Based on the patent’s specification, Petitioner contended the term should be construed as "a controller that receives input from a telephone." This construction was presented as critical to distinguish it from an incorrect interpretation where the device controls a telephone. The proposed construction aligns with the prior art systems where a phone acts as a transmitter sending a signal to a control box at the trap site.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-28 of the ’228 patent as unpatentable.