PTAB

IPR2025-01032

Revelyst Sales LLC v. BRAInguard Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Helmet with Sliding Layers for Impact Protection
  • Brief Description: The ’635 patent is directed to helmets with multiple layers designed to slide relative to each other to increase protection against impact forces, particularly rotational acceleration. The layers are connected by "energy and impact transformer" layers that facilitate this relative movement and absorb energy.

3. Grounds for Unpatentability

Ground 1: Obviousness over Weber and Puchalski - Claims 1-4, 6, 8-12, 14, and 16-20 are obvious over Weber in view of Puchalski.

  • Prior Art Relied Upon: Weber (Application # US2012/0198604) and Puchalski (6,996,856).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Weber taught the core elements of the challenged claims. Weber disclosed a multi-layered helmet with an outer shell, an outer liner, an intermediate liner, and an inner liner designed to reduce rotational and linear forces. These layers were separated by "isolation dampers" that permitted "controlled internal omnidirectional relative displacement," functioning as the claimed "shear mechanism" and "energy transformer." The dampers and the air gaps between layers were made of absorptive/dissipative materials. Weber’s inner liner was configured to conform to a wearer’s head.
    • Motivation to Combine: While Weber disclosed using a conventional chin strap for restraint, it did not specify the attachment point. Puchalski, which addresses the same problem of helmet safety with sliding layers, taught that a chin strap is "most preferably" secured to the inner panel. A POSITA would combine Puchalski’s specific, preferred chin strap attachment with Weber’s helmet design as an obvious design choice to ensure the helmet remains properly and securely positioned on the wearer’s head while allowing the outer layers to slide during impact.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, as attaching a chin strap to the inner layer of a multi-layer helmet was a conventional and well-understood technique involving a finite number of design choices.

Ground 2: Obviousness over Von Holst, Halldin, and Puchalski - Claims 1-4, 6, 8-12, 14, and 16-20 are obvious over Von Holst in view of Halldin and Puchalski.

  • Prior Art Relied Upon: Von Holst (WO 01/45526), Halldin (WO 2011/139224), and Puchalski (6,996,856).
  • Core Argument for this Ground:
    • Prior Art Mapping: Von Holst taught a protective helmet with an outer shell and an inner shell separated by an intermediate "sliding layer" (e.g., oil or air) that allows the outer shell to be displaced relative to the inner shell to absorb rotational energy. Halldin, which shares an inventor with Von Holst, taught using internal "fixation members" that connect helmet layers, absorb energy by deforming, and allow the layers to slide relative to each other. Petitioner argued the combination of Von Holst’s sliding layers with Halldin’s internal fixation members disclosed the claimed shear mechanism and energy transformer. Puchalski was cited for its teaching of attaching a chin strap to the inner layer.
    • Motivation to Combine: Both Von Holst and Halldin addressed the same problem of reducing rotational impact using sliding helmet mechanisms. A POSITA would be motivated to modify Von Holst by incorporating Halldin's internal fixation members to improve the connection between layers and provide additional energy absorption, a known alternative to Von Holst's peripheral connectors. The addition of Puchalski's chin strap attachment was motivated by the same reasons as in Ground 1.
    • Expectation of Success: A POSITA would have expected success in combining the references, as Halldin’s fixation members were readily applicable to Von Holst’s sliding layer design. This combination was a matter of routine implementation to achieve predictable results.

Ground 3: Anticipation by Dotsuko - Claims 1-3, 9-11, and 17-19 are anticipated by Dotsuko.

  • Prior Art Relied Upon: Dotsuko (JP Application # 2006/016740).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Dotsuko disclosed every element of the challenged claims. Dotsuko’s helmet included an "outermost shell" and "outer liner" (outer shell layer) and an "inner liner" (inner shell layer). These layers were connected by a shear mechanism comprising multiple elastic straps and an elastic, gel-like body within a space between the layers. This mechanism allowed "relative rotation" of the outer shell upon impact. The deformable elastic body and elongating straps functioned as the "first energy transformer" with absorptive/dissipative material. Crucially, Dotsuko explicitly disclosed a "chin-strap attached to the...inner liner" to ensure the inner liner "remains in place while the shell[] alone relatively rotates," directly teaching the final limitation of independent claim 1.

  • Additional Grounds: Petitioner asserted additional challenges, including that claims 1-4, 6, 8-12, 14, and 16-20 are obvious over Kleiven in view of Puchalski; claims 8 and 16 are obvious over Dotsuko in view of Puchalski; and that claims 1-3, 8-11, and 16-19 are anticipated by Madey.

4. Key Claim Construction Positions

  • Petitioner argued that claim terms should be given their plain and customary meaning. Specifically for the term "shear mechanism," Petitioner contended it means something that shears and allows the outer shell layer to slide relative to the inner shell layer. Petitioner noted that dependent claim 2, which recites "the shear mechanism is a shear layer," clarifies that the mechanism can be a layer that shears.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6, 8-12, 14, and 16-20 of the ’635 patent as unpatentable.