ARoma 360 LLC v. Air Esscentials Inc

1. Case Identification

• Case #: IPR2025-00707
• Patent #: 10,092,918
• Filed: March 18, 2025
• Petitioner(s): Aroma360, LLC
• Patent Owner(s): Air Esscentials, Inc.
• Challenged Claims: 1, 3-8

2. Patent Overview

• Title: Fluid Dispersion Assembly
• Brief Description: The ’918 patent is directed to a fluid dispersion assembly, such as an aroma diffuser, designed to reduce operational noise and generate a fluid dispersion with a uniform particle size. The patent discloses various embodiments where a diffusion unit with distinct chamber configurations disrupts the flow path of the atomized fluid to dampen sound waves.

3. Grounds for Unpatentability

Ground 1: Obviousness over Goubet - Claims 1 and 3-8 are obvious over Goubet.

• Prior Art Relied Upon: Goubet (French Patent Publication No. 2886160).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Goubet, an essential oil diffuser, teaches all limitations of the challenged claims. Goubet’s “diffuser head” was identified as the claimed “diffusion unit,” which contains at least two concentric circular enclosures (outer enclosure 12, inner enclosure 13) that Petitioner mapped to the claimed upper and lower chambers. The combination of Goubet's air inlet, dip tube, and diffusion chamber was argued to constitute the claimed “atomizer assembly” disposed between the upper and lower chambers. Petitioner contended that the path for breaking oil droplets into microdroplets within Goubet’s enclosures meets the “fluid dispersion” limitation.
  • Motivation to Combine: As a single-reference ground, the argument was that Goubet inherently teaches all limitations. For claim 4, which requires the formation of “substantially uniform” droplets, Petitioner argued a POSITA would have understood that Goubet’s stated goal of reducing droplet size “as much as possible” via a baffled circular path would inherently result in more uniform droplets. If not inherently disclosed, a POSITA would have been motivated by Goubet’s objective to add more circular enclosures to further reduce droplet size and improve uniformity.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in modifying Goubet to add enclosures, as it would not require undue experimentation and aligns with the reference’s own design principles for improving diffusion.

Ground 2: Obviousness over Gao-2 - Claims 1 and 3-8 are obvious over Gao-2.

• Prior Art Relied Upon: Gao-2 (Chinese Utility Model Patent 204072864).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that Gao-2, an aroma diffuser, discloses the claimed invention. Gao-2’s atomization device includes a cylindrical body (the “diffusion unit”) that is explicitly divided by a “partition plate” into an “upper chamber” and a “lower chamber.” The “atomization core” of Gao-2 was mapped to the claimed “atomizer assembly,” which is disposed on the partition plate between the two chambers. Petitioner argued that Gao-2’s design, which atomizes droplets downward so only “fine fragrant mist” rises through noise-reduction baffles before exiting a mist outlet, meets the “fluid dispersion” limitation.
  • Motivation to Combine: This is a single-reference ground. Petitioner contended that a POSITA would understand that Gao-2’s method of separating coarse mist from fine mist via baffles would produce droplets of substantially uniform size. Gao-2’s stated purpose was to overcome the known problem of large perfume particles in prior art diffusers. If the resulting mist was not already uniform, a POSITA would be motivated by Gao-2’s objective to add more baffles to further reduce droplet size and improve uniformity.
  • Expectation of Success: A POSITA would expect success in adding more baffles, as Gao-2 itself suggests using one or more noise reduction devices, and this modification would predictably result in smaller, more uniform droplets.

• Additional Grounds: Petitioner asserted two additional obviousness grounds as alternatives. Ground 2 argued that claims 1 and 3-8 are obvious over Goubet in view of Kaiser (a 2003 article on electrospray), with Kaiser being used to explicitly teach the well-known benefits of uniform droplet size for dispersion if Goubet alone was deemed insufficient. Ground 4 argued that claims 1 and 3-8 are obvious over Gao-2 in view of Goubet, proposing a POSITA would be motivated to replace Gao-2's baffles with Goubet's spiraling enclosure design to further improve droplet size reduction and uniformity.

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner contended that the challenged claims are not entitled to their earliest asserted priority date. It argued that key limitations, including the "upper chamber," "lower chamber," and "atomizer exhaust aperture," constitute new matter first disclosed in a continuation-in-part application filed on November 17, 2016. This later effective filing date is critical for establishing that Gao-2, published in January 2015, qualifies as prior art against the challenged claims.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate.
• Under §325(d): Petitioner asserted that the grounds rely on prior art (Goubet, Gao-2, Kaiser) and arguments that were not previously presented to or considered by the USPTO during prosecution.
• Under §314(a) (Fintiv): Petitioner stipulated that if the Board institutes this inter partes review (IPR), it will not seek resolution in the parallel district court litigation on any invalidity ground that was raised or could have been reasonably raised in the petition.

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1 and 3-8 of Patent 10,092,918 as unpatentable.