PTAB

IPR2025-01018

Klein Tools Inc v. Milwaukee Electric Tool Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Container Assembly
  • Brief Description: The ’167 patent relates to a modular utility assembly of two or more detachably connectable containers. The system uses a coupling mechanism where a male coupler on the bottom of one container slidingly engages a female coupler on the lid of another, secured by a locking latch that engages an arresting location.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1, 5-7, and 10-16 over Burchia, Metabowerke, Welsh (or Chen), and Lin

  • Prior Art Relied Upon: Burchia (Patent 10,750,833), Metabowerke (German Patent No. 20 2014 103 695 U1), Welsh (Application # US 2007/0138041), Chen (Application # US 2014/0265440), and Lin (Patent 9,375,835).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Burchia disclosed the core elements of a container assembly as claimed, including two containers with pivotally attached lids, a male coupler sliding into a female coupler, and a spring-biased locking latch with an arresting location. To the extent Burchia’s female coupler design was disputed, Metabowerke taught an alternative but analogous coupler with a depressed surface, back wall, sidewalls, and rib. For limitations not in Burchia, Petitioner asserted Welsh and Chen disclosed adding protective corner bumpers (claims 1[e]-[g], 5), while Lin taught modular containers of different sizes, specifically a half-width container (claim 1[n]), to achieve modular compatibility.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to achieve predictable benefits. A POSITA would incorporate Metabowerke’s smaller, flush female coupler into Burchia’s system to reduce the risk of damage and preserve space. Adding corner bumpers from Welsh or Chen was argued to be an obvious design choice to protect toolboxes from impacts. Incorporating Lin’s half-width containers into Burchia’s system would have been an obvious way to maximize interchangeability and stacking efficiency for holding smaller tools.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success as all references relate to the analogous art of releasably stackable containers and involve simple, predictable mechanical integrations.

Ground 2: Obviousness of Claims 2-4 and 8-9 over Burchia, Metabowerke, Welsh (or Chen), Lin, and Bensman

  • Prior Art Relied Upon: The references from Ground 1, further in view of Bensman (Application # 2013/0127129).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address claims related to mobility and lid latching. Petitioner argued that while Burchia did not disclose wheels or a telescoping handle, Bensman taught a container system with both features. A POSITA would add these to Burchia's container to improve mobility, thereby rendering claim 2 obvious. For claims 8 and 9, which required four "toggle locking latches," Petitioner asserted that Burchia’s "closure latches" met the limitation. Alternatively, if they did not, Bensman explicitly disclosed toggle locking latches, and the examiner in a related patent prosecution had already found it to be an "obvious variation" to add such latches.
    • Motivation to Combine: A POSITA would be motivated to add the wheels and telescoping handle from Bensman to the heavy, stackable containers of Burchia to facilitate mobility, a common problem in the field. The motivation to use Bensman’s toggle latches stemmed from their ubiquity and the predictable result of securely closing a toolbox lid, which a POSITA would find to be an obvious design choice.
    • Expectation of Success: Adding wheels, handles, and standard latches to a toolbox was presented as a straightforward mechanical modification with highly predictable and beneficial results.

Ground 3: Obviousness of Claims 1, 5-7, and 10-16 over Metabowerke, Burchia, Welsh (or Chen), and Lin

  • Prior Art Relied Upon: The same references as Ground 1, but with Metabowerke as the primary reference.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Metabowerke served as an alternative primary reference, disclosing a stackable container system with male and female couplers and a locking latch that engaged a coupling tab (the arresting location). While Metabowerke's latch was manual, Petitioner asserted it would have been obvious to modify it by incorporating the spring-biased automatic locking latch from Burchia for improved convenience. The remaining limitations related to corner bumpers (from Welsh/Chen) and half-width modularity (from Lin) were addressed with the same rationale as in Ground 1.
    • Motivation to Combine: A POSITA would combine Metabowerke with Burchia to improve functionality. Incorporating Burchia's spring-biased latch would enable automatic locking upon stacking and eliminate the need to manually unlatch and re-latch the system, which was described as a significant improvement in convenience.
    • Expectation of Success: Because both Metabowerke and Burchia taught similar stackable container systems with sliding couplers, substituting one type of known latching mechanism (manual toggle) for another (spring-biased) was a simple design choice with a predictable outcome.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Lafragette (Application # 2003/0139080) as an alternative source for a recessed "arresting location" and other permutations of the primary references.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-16 of Patent 11,952,167 as unpatentable.