PTAB

IPR2025-01033

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 Rotational Impact Protection
  • Brief Description: The ’909 patent is directed to protective helmets featuring multiple layers designed to slide relative to one another upon impact. This relative movement is intended to absorb energy and reduce damaging rotational forces on the wearer's head.

3. Grounds for Unpatentability

Ground 1: Obviousness over Weber and Puchalski - Claims 1-2, 8-13, and 19-20 are obvious over Weber in view of Puchalski.

  • Prior Art Relied Upon: Weber (Application # US2012/0198604) and Puchalski (Patent 6,996,856).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Weber disclosed all elements of the challenged claims except for the specific attachment point of a chin strap. Weber taught a multi-layered helmet with an outer shell, an inner liner (inner protective shell), and an intermediate layer of "isolation dampers" and fluid. Petitioner contended this intermediate layer functions as the claimed "shear mechanism" and "energy transformer layer" by allowing the outer and inner shells to move relative to each other to dissipate rotational and linear forces. Weber also described a comfort liner and the use of a conventional chin strap for proper restraint.
    • Motivation to Combine: Petitioner asserted that while Weber mentioned a chin strap, it did not specify its attachment point. Puchalski, which addresses the same problem of impact absorption in helmets, was cited for its express teaching that a chin strap is "most preferably...secured to the peripheral edge of the inner panel." Petitioner argued a person of ordinary skill in the art (POSITA) would combine Puchalski’s specific chin strap placement with Weber’s helmet design. This modification would solve the known problem of ensuring a stable fit on the wearer’s head while preserving the critical function of allowing the outer shell to slide relative to the inner shell upon impact.
    • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success because attaching a chin strap to the innermost structural layer was a well-known, conventional technique. It represented an obvious design choice from a finite number of options to achieve the predictable result of a secure fit.

Ground 2: Obviousness over Von Holst, Halldin, and Puchalski - Claims 1-2, 5, 8-9, 11-13, 16, and 19-20 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 (Patent 6,996,856).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner alleged that Von Holst disclosed the basic structure of a multi-layer helmet with an outer shell, inner shell, and an intermediate "sliding layer 4" that allows for relative displacement to absorb rotational energy. Halldin, which shares a common inventor with Von Holst, was introduced for its teaching of specific "fixation members" that connect helmet layers, absorb energy through deformation, and facilitate sliding. The combination of Von Holst's structure with Halldin's fixation members was argued to teach the claimed "shear mechanism" and "energy transformer layer."
    • Motivation to Combine: A POSITA would combine these references to improve upon Von Holst’s design. Halldin, being later-filed and from the same inventor, represented a technological advancement in connecting sliding layers. A POSITA would be motivated to incorporate Halldin's more sophisticated, energy-absorbing fixation members into Von Holst's helmet to enhance both the connection between layers and the overall energy absorption capabilities. Puchalski was added for the same reason as in Ground 1: to supply the explicit teaching of securing the chin strap to the inner shell for optimal fit and stability.
    • Expectation of Success: The combination was argued to be predictable. Halldin’s fixation members were designed for the express purpose of connecting layers in helmets of this type and could be readily adapted into Von Holst’s system as a matter of routine implementation to achieve improved performance.

Ground 3: Anticipation by Madey - Claims 1-2, 4-5, 8-10, 12-13, 15-16, and 19-20 are anticipated by Madey.

  • Prior Art Relied Upon: Madey (Application # US2004/0117896).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Madey disclosed every element of the challenged claims arranged as claimed. Madey taught a helmet with an outer helmet layer and an inner helmet layer separated by an "interface layer." This interface layer, comprising "hyper-elastic columns," was alleged to perform the functions of both the claimed "shear mechanism" and "energy transformer layer." The columns were designed to bend and stretch in response to tangential forces, allowing the outer layer to displace relative to the inner layer and thereby absorb and divert impact forces. Critically, Madey also explicitly disclosed a helmet retention system, including straps that function as a chin strap, affixed to the inner helmet layer to secure it to the wearer's head.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Kleiven combined with Puchalski, and Dotsuko combined with Puchalski, relying on similar design modification theories for integrating known chin-strap attachment points into multi-layer sliding helmet designs.

4. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-2, 4-5, 8-13, 15-16, and 19-20 of the ’909 patent as unpatentable.