PTAB

IPR2025-00724

Milwaukee Electric Tool Corp v. Klein Tools Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Safety Helmet with Accessory Receptacles
  • Brief Description: The ’327 patent discloses a safety helmet featuring an outer shell with front and rear receptacles for detachably mounting accessories, such as headlamps. The key claimed features include the receptacles having an external slot and a protruding nub that is integrally molded with the outer shell from a common material.

3. Grounds for Unpatentability

Ground 1: Claims 1-17 are obvious over Yan in view of Daley.

  • Prior Art Relied Upon: Yan (Chinese Utility Model Application No. 201120014896.0) and Daley (Patent 9,993,043).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Yan taught the foundational safety helmet, disclosing a helmet body with a brim and both front and rear "snap-fit slots" (the claimed receptacles) for detachably mounting accessories like lamps. However, Yan lacked the claimed integrally molded protruding nub. Daley allegedly supplied this missing element, teaching a safety helmet with an integrally molded receptacle that includes locking ears (forming an external slot) and a central "protrusion 43b" (the claimed nub) to securely fasten a headlight. The combination of Yan’s dual-receptacle helmet with Daley’s integrally molded nub feature was asserted to render all limitations of claim 1 obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would have been motivated to combine the references to solve the known problem of accessories slipping off helmets. Petitioner contended that Yan expressly invited "equivalent structural modifications," which would lead a POSA to Daley's superior mounting mechanism. Incorporating Daley’s integrally molded protrusion into Yan’s design would create a more robust and commercially desirable product by improving the security of mounted accessories.
    • Expectation of Success: A POSA would have had a reasonable expectation of success because the combination involved applying Daley's known integral molding techniques to Yan's helmet, a straightforward modification with predictable results.

Ground 2: Claims 1-17 are obvious over Yan in view of Nesbitt.

  • Prior Art Relied Upon: Yan and Nesbitt (Patent 4,304,009).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative to Daley for teaching the protruding nub. As in Ground 1, Yan provided the base helmet with front and rear snap-fit slots. Nesbitt was argued to teach a safety helmet made of polyethylene with a plurality of integrally molded sockets, each containing a "nub 32" for detachably retaining accessories. Petitioner asserted that modifying Yan’s helmet to include Nesbitt's integrally molded nubs within each snap-fit slot rendered the claims obvious.
    • Motivation to Combine: The motivation was analogous to that in the Yan/Daley combination. A POSA seeking to improve the accessory mounting security of Yan’s helmet would have looked to analogous art like Nesbitt. They would have been motivated to incorporate Nesbitt's integrally molded nub feature into both of Yan's receptacles to create a more robust helmet, which would be cheaper and easier to manufacture.
    • Expectation of Success: The modification was presented as a routine design choice for a POSA, involving the application of known molding methods to combine existing features, leading to a predictable improvement in accessory retention.

Ground 3: Claims 1-17 are anticipated by the Klein News Release.

  • Prior Art Relied Upon: Klein News Release, published July 23, 2019 (“KNR”).

  • Core Argument for this Ground: This ground was based on a challenge to the ’327 patent’s claimed priority date of January 26, 2018.

    • Priority Date Challenge: Petitioner argued that critical claim limitations—specifically that the "protruding nub is integrally molded with the outer shell from the common material"—were not supported by the original priority applications. This language was allegedly added as new matter during prosecution in October 2021 and April 2022. Consequently, Petitioner contended the challenged claims are only entitled to an effective filing date of October 21, 2021, at the earliest.
    • Prior Art Mapping: With the priority date shifted to October 2021, the KNR (published July 2019) qualifies as prior art under 35 U.S.C. §102. Petitioner asserted that the KNR, which described Patent Owner’s own commercial safety helmets, disclosed every element of the challenged claims. The KNR included images and descriptions of helmets with "Patent-pending accessory mounts on front and back," showing the claimed outer shell, brim, front and rear receptacles, and mounted accessories, thereby anticipating claims 1-17.

  • Additional Grounds: Petitioner asserted that claims 2, 4, 9, and 12 are obvious over Yan and Daley in view of Kiessler (German Utility Model App. No. 2020-06007009). Kiessler was used to teach an alternative clip-based mounting system with a clamping lever and a corresponding groove head (protruding nub) to further improve accessory security and adjustability.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-17 of the ’327 patent as unpatentable.