PTAB

IPR2025-01016

ROBE Lighting SRO v. Guangzhou HaoYang Electronic Co Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Light Fixture with Self-Test Ability of Sealing
  • Brief Description: The ’373 patent discloses stage lighting fixtures with an integrated system for self-testing the integrity of their environmental seals. The system uses internal temperature and pressure sensors to detect leaks after the fixture is sealed and heated by its own light source or other components.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-4, 6, 10, and 11 by Jurik

  • Prior Art Relied Upon: Jurik (Patent 12,085,267).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Jurik, which describes a system for controlling humidity and pressure in a luminaire, discloses every element of independent claim 1 and its dependents. Jurik’s luminaire is a light fixture with a self-test capability that functions by sealing the unit and monitoring internal pressure changes. Petitioner mapped Jurik’s head enclosure, light source, temperature/pressure sensors, and control system directly to the corresponding limitations of claim 1. Critically, Jurik’s remotely operable electromagnetic valve (719/819) and hydrophobic membrane (210/410) were argued to meet the claimed “switch” and “waterproof breathable valve” limitations, respectively. The switch is configured to block the valve during a sealing test and unblock it for normal operation, directly corresponding to claim 1’s functional requirements.
    • Key Aspects: Petitioner contended that dependent claims 2-4, 6, 10, and 11 are also anticipated, as Jurik explicitly discloses common features like effect assemblies (claim 2), light-blocking shutters (claim 3), a support arm and base structure (claim 4), sealed pipelines between enclosures (claim 6), auxiliary heating elements (claim 10), and an electromagnetic valve (claim 11).

Ground 2: Obviousness of Claims 5, 12, and 13 over Jurik, or Jurik in view of Johansen

  • Prior Art Relied Upon: Jurik (Patent 12,085,267) and Johansen (Patent 9,777,917).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground challenged claims related to adding a separate self-test system to the fixture’s base housing. Petitioner asserted that Jurik discloses power supplies and the potential placement of sensors in its base enclosure. The use of a switching mode power supply (claim 5a) was argued to be an obvious, well-known design choice for efficiency. For claim 5c’s “additional waterproof breathable valve” on the base, Petitioner argued this would be an obvious modification to Jurik to add redundancy or enable isolated testing of the base enclosure. Alternatively, Johansen taught using separate dehumidifying systems (functioning as waterproof valves) on both the head and base of a similar lighting fixture. Claims 12 and 13, which add a heat homogenizing assembly (e.g., a fan) and an auxiliary heating assembly to the base, were argued to be taught by Jurik, which discloses cooling fans and heat-generating power supplies within its base enclosure.
    • Motivation to Combine (for Jurik + Johansen): A person of ordinary skill in the art (POSITA) seeking to improve the robustness of Jurik’s single-vent system would be motivated by Johansen’s disclosure of separate environmental controls for the head and base. This would lead a POSITA to add a second, independent valve system to Jurik’s base to improve reliability and allow for isolated diagnostics, a predictable design improvement.
    • Expectation of Success: The proposed modifications involved applying known components (valves, fans, power supplies) for their intended purposes in a predictable manner, ensuring a high expectation of success.

Ground 3: Obviousness of Claims 7 and 8 over Jurik

  • Prior Art Relied Upon: Jurik (Patent 12,085,267).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims adding a blocking device within the pipeline between the head and base (claim 7) and a system for synchronously increasing temperature in both housings (claim 8). Petitioner argued that while Jurik’s pipeline is open, a POSITA would find it obvious to add a “blocking device” (e.g., another electromagnetic valve) to isolate the enclosures. For claim 8, Jurik discloses heating elements in both its head (light source) and base (power supplies). Petitioner asserted it would have been obvious to configure Jurik’s controller to activate all heating elements simultaneously to conduct the sealing test more quickly and evenly.
    • Motivation to Combine: The motivation for adding a blocking device (claim 7) was to improve the diagnostic capability of Jurik’s system, allowing a user to pinpoint a leak to either the head or the base, thereby saving maintenance costs. The motivation for synchronous heating (claim 8) was to improve the efficiency and accuracy of the sealing test by reducing test time and ensuring a more uniform temperature increase.
    • Expectation of Success: Implementing these features would involve adding a standard valve or modifying control software, both routine engineering tasks with predictable outcomes.

  • Additional Grounds: Petitioner asserted a challenge to claim 9 as anticipated by Jurik, or alternatively, obvious over Jurik in view of Jurik 2 (Application # 2015/0103553), arguing Jurik’s drawings show heat-homogenizing fans in the head enclosure and that adding such fans was an exceedingly common practice.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of the ’373 patent as unpatentable.