SharkNinja Inc v. Dyson Technology Ltd

1. Case Identification

• Case #: IPR2023-01323
• Patent #: 11,589,660
• Filed: August 18, 2023
• Petitioner(s): SharkNinja, Inc., SharkNinja Operating LLC, SharkNinja Management LLC, and SharkNinja Sales Company
• Patent Owner(s): Dyson Technology Limited
• Challenged Claims: 1-9, 15, 18, 23, 24, and 30-34

2. Patent Overview

• Title: Handheld Appliance
• Brief Description: The ’660 patent discloses a connection mechanism for a handheld appliance, such as a hair styling device, and a removable attachment. The purported improvement over traditional bayonet fittings is a curved slot on the appliance body that allows for a secure, yet easily removable, connection via a protrusion on the attachment and a slidable actuator.

3. Grounds for Unpatentability

Ground 1: Anticipation over Hoblingre - Claims 1-9, 15, 23, 24, and 32 are anticipated by Hoblingre

• Prior Art Relied Upon: Hoblingre (Patent 4,943,182).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Hoblingre, which discloses a “rapid fastener of the bayonet type,” teaches every element of the challenged claims. Hoblingre’s “second shaft 2,” comprising a “socket 8” and a spring-biased, slidable “ring 18,” was asserted to be the claimed “body” with an “actuator.” The “first shaft 1” with its “driving pin 6” was mapped to the claimed “attachment” with a “first protrusion.” Critically, Petitioner contended that Hoblingre’s “curved” and “helical” slot 12, which has both an axial entrance portion and a helical portion, satisfies the limitation of a “first slot” that “extends both radially around and axially along the body,” thereby anticipating the core feature of independent claim 1. Dependent claims were allegedly met by Hoblingre’s disclosure of the actuator ring partially obscuring the slot (claim 2), the actuator interacting with the pin (claim 3), and the spring biasing the actuator (claim 9).

Ground 2: Anticipation over Mouhot - Claims 1-9, 15, 23, 24, and 32 are anticipated by Mouhot

• Prior Art Relied Upon: Mouhot (EP 0 791 758 A1).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Mouhot, disclosing a “bayonet-type quick coupler,” also anticipates all limitations of the same set of claims. Mouhot’s first component, comprising a “socket 2” and “locking means 4” (a ring and spring), was argued to be the claimed “body” and “actuator.” Mouhot’s second component, a “shank 3” with a “lateral protruding part 6,” was identified as the claimed “attachment” and “first protrusion.” Petitioner argued that Mouhot’s slot configuration, comprising an “axial slot” (e.g., slot 7) that leads into a lateral “stop means” (e.g., stop means 9), meets the claim 1 limitation for a slot extending both axially and radially. The slidable, spring-biased nature of Mouhot’s locking ring was argued to meet the limitations for the actuator’s movement and biasing.

Ground 3: Obviousness over Hoblingre, Maclaine, and Jeannet - Claims 1-9, 15, 18, 23, 24, and 30-34 are obvious over Hoblingre, Maclaine, and Jeannet

• Prior Art Relied Upon: Hoblingre (Patent 4,943,182), Maclaine (Application # 2015/0265022), and Jeannet (Patent 6,161,244).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground builds on the combination of Hoblingre and Maclaine, with Hoblingre providing the core bayonet fastener mechanism and Maclaine providing the context of a handheld hair care appliance with interchangeable attachments. Petitioner asserted that Jeannet, which discloses a bayonet catch for a toothbrush, renders obvious the addition of a “user operated button” as recited in claims 33 and 34. Jeannet explicitly teaches an “unlocking button 121” that slides longitudinally to release the bayonet connection, which Petitioner argued directly corresponds to the button limitation.
  • Motivation to Combine: A POSITA would combine these references to improve the usability of the hair care appliance taught by Maclaine. Maclaine suggests using interchangeable heads, creating a need for an easy and efficient release mechanism. A POSITA would look to known release mechanisms in analogous arts, such as the toothbrush in Jeannet, and find motivation to incorporate a simple, user-friendly button to facilitate the quick-release function desirable in Maclaine’s system.
  • Expectation of Success: Petitioner argued there would be a high expectation of success, as adding a simple mechanical button (Jeannet) to an existing slidable ring actuator (Hoblingre) is a simple addition of a known element to perform its known function, yielding predictable results.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including Ground 2 (Hoblingre and Maclaine), Ground 5 (Mouhot and Maclaine), and Ground 6 (Mouhot, Maclaine, and Jeannet), which relied on similar substitution and design choice rationales to adapt the base Hoblingre or Mouhot mechanisms for use in a handheld hair care appliance.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §314(a) by stating that the petition was filed before any infringement complaint, making the Fintiv factors weigh in favor of institution.
• Petitioner also argued against discretionary denial under §325(d), contending that the arguments are new and non-cumulative because none of the primary prior art references (Hoblingre, Mouhot, Maclaine, Jeannet) were cited or considered during the original prosecution of the ’660 patent.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-9, 15, 18, 23, 24, and 30-34 of the ’660 patent as unpatentable.