W W Mfg Co Inc v. Jager Pro Inc

1. Case Identification

• Case #: Unassigned
• Patent #: 10,098,339
• Filed: August 14, 2020
• Petitioner(s): W-W-MANUFACTURING CO., INC.
• Patent Owner(s): Jager Pro, Inc.
• Challenged Claims: 1-20

2. Patent Overview

• Title: Systems and Methods for Animal Trapping
• Brief Description: The ’339 patent discloses systems for remotely capturing wild animals, such as feral pigs. The system comprises an enclosure with a movable gate, a camera assembly for monitoring the enclosure, and a remote display device that allows a user to receive a wireless detection signal and transmit a wireless control signal to trigger the gate.

3. Grounds for Unpatentability

Ground 1: Obviousness over TB1, TB2, Jeong, and Vorhies - Claims 1, 3, 4, and 14-18 are obvious over TB1 in view of TB2, Jeong, and optionally Vorhies.

• Prior Art Relied Upon: The Trapping Webpage (“TB1”), The TexasBoars “How to Build a Wild Hog Trap” Presentation (“TB2”), 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") discloses the basic physical structure of the claimed invention: a large, floorless corral-style trap with a movable guillotine-style door for capturing wild pigs. Petitioner asserted that Jeong teaches all remaining elements of independent claim 1, including adding a remote monitoring and control system to an animal trap. Specifically, Jeong was said to disclose a camera assembly that transmits a wireless signal to a remote display device, allowing an operator to monitor the trap and transmit a control signal to trigger a capture unit (e.g., a solenoid) and close the gate. Vorhies was presented as an alternative reference teaching the use of wireless signal transmission (RF signals) for remote trap management.
  • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine the basic trap of the TexasBoars Combination with the remote monitoring and control system of Jeong to solve a known problem with mechanical traps. Specifically, it would replace a passive, animal-activated tripwire with an active, user-controlled trigger, thereby increasing the probability of successfully capturing an entire group of animals by allowing the operator to wait for the optimal moment to close the gate.
  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because the combination involves substituting one known triggering element (a mechanical tripwire) with another known triggering element (an electro-mechanical remote control system) to achieve a predictable improvement in trap control and efficacy.

Ground 2: Obviousness over TexasBoars, Jeong, Vorhies, and Silsby - Claims 5-10 are obvious over the combination of Ground 1 further in view of Silsby.

• Prior Art Relied Upon: TB1, TB2, Jeong, Vorhies, and Silsby (Application # 2006/0203101).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds upon the combination in Ground 1. Petitioner argued that Silsby teaches the specific limitations of dependent claims 5-10. Silsby discloses a motion-detecting camera system where the "base unit" for receiving images and controlling the system is a wireless handheld device, specifically a cellular telephone. Silsby further teaches that the detection and control signals are transmitted via a cellular network. It also discloses incorporating a motion sensor to detect the presence of animals, which can trigger the camera.
  • Motivation to Combine (for §103 grounds): A POSITA would be motivated to use the cellular telephone-based system of Silsby as the remote-control unit for the trap system of Ground 1. Silsby itself touts cellular phones as simple, reliable, portable, and easy-to-use devices for remote monitoring. This modification would provide a convenient and widely available interface for the trap system, leveraging existing cellular infrastructure.
  • Expectation of Success (for §103 grounds): A POSITA would expect success in integrating Silsby’s teachings, as it simply involves using a known type of remote-control device (a cell phone) for its intended purpose of remote monitoring and control.

Ground 3: Obviousness over TexasBoars, Jeong, Vorhies, and Additional Components - Claims 2, 11, 12, 19, and 20 are obvious over the combination of Ground 1 further in view of Kimura or Thomas.

• Prior Art Relied Upon: TB1, TB2, Jeong, Vorhies, and either Kimura (Japanese Application # 2004-97019) or Thomas (Application # 2008/0236023).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that Kimura and Thomas teach specific hardware components recited in the remaining dependent claims. For claims 11, 12, and 19, Petitioner argued Kimura discloses using an "internet protocol web camera" to transmit image data over a wireless internet network to a remote terminal, such as a mobile phone. For claims 2 and 20, Petitioner argued Thomas discloses the specifics of the control mechanism, teaching the use of a relay and a battery to power a solenoid that triggers the trap in response to a remote signal.
  • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate Kimura’s internet-based camera to use a standard, well-known communication protocol for transmitting video from the trap. A POSITA would be motivated to incorporate the relay-and-battery-powered solenoid from Thomas as it represents a conventional, effective, and common electrical arrangement for activating a trap mechanism, particularly in remote locations lacking mains power.
  • Expectation of Success (for §103 grounds): A POSITA would expect predictable results from integrating these standard electronic components into the known trap system to perform their conventional functions.

• Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 13 (Ground 5) based on the combined teachings of all the above references, arguing that the remote-control unit of Jeong inherently possesses the capabilities of a "computer" and that Silsby explicitly teaches using a laptop computer as a base unit.

4. Key Claim Construction Positions

• "telephone controller": Petitioner argued this term should be construed as "a controller that receives input from a telephone." Petitioner contended that a plain reading might incorrectly suggest a device that controls a telephone. However, the ’339 patent specification allegedly clarifies that the "cell phone" acts as a transmitter, while the "cell phone controller" acts as a receiver at the trap site, making it a controller that is controlled by a telephone, not one that controls a telephone.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of Patent 10,098,339 as unpatentable under 35 U.S.C. §103.