PTAB

IPR2025-01095

Baby Generation Inc v. Baby Jogger LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Stroller System
  • Brief Description: The ’231 patent relates to a stroller system capable of supporting both a front and a rear stroller seat. The system features a frame with a handle portion, front and rear wheel support portions, and a folding mechanism, with a key disputed limitation requiring the handle and front wheel support portions to be "substantially parallel" in the unfolded configuration.

3. Grounds for Unpatentability

Ground 1: Claims 1-17 and 19-22 are obvious over Dotsey in view of Zehfuss.

  • Prior Art Relied Upon: Dotsey (Application # 2009/0127810) and Zehfuss (Application # 2010/0140902).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that this ground is predicated on the ’231 patent’s effective filing date being its actual filing date of July 29, 2022, making Zehfuss (published 2010) prior art. Dotsey allegedly disclosed the core stroller frame, including a handle portion and front wheel support portion that are "substantially parallel." However, Dotsey did not teach mounting a second, convertible seat. Zehfuss supplied this missing element by teaching a front seat attachment that allows a second seat to be supported in forward- or rear-facing configurations and positioned over the front wheels to ensure the stroller’s center of gravity is between the front and rear wheels for stability.
    • Motivation to Combine (for 35 U.S.C. §103 grounds): A POSITA would combine the references to satisfy known market demand for convertible double strollers. Zehfuss explicitly taught using its front seat attachment to convert a single stroller into a double stroller. A POSITA would have also been motivated to incorporate Zehfuss’s teaching on seat positioning to improve the stability and prevent tipping in the combined Dotsey design.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because both references disclosed conventional stroller components, making the integration of Zehfuss’s seat attachment onto Dotsey’s frame a straightforward application of known design principles.

Ground 2: Claims 1-17 and 19-22 are obvious over Van Dijk in view of Schaaf.

  • Prior Art Relied Upon: Van Dijk (Application # 2007/0194545) and Schaaf (Patent 6,209,892).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Van Dijk disclosed a stroller system with versatile seat mounting mechanisms ("adapters" and "connecting pieces") allowing different seat types to be attached in various configurations. Schaaf taught a collapsible, inline double stroller frame where seats are mounted at specific front and rear locations. The combination allegedly rendered all claim limitations obvious. Specifically, a POSITA would use two sets of Van Dijk's mounting mechanisms and place them on the frame at the locations taught by Schaaf to create an inline double stroller. Furthermore, if the Board found Van Dijk's frame members were not "substantially parallel," Schaaf taught this feature by disclosing axially parallel frame segments.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the references to create a multi-child stroller system, a product for which there was known demand. The combination would modify Van Dijk’s single-seat system to support two seats using the inline configuration from Schaaf. Additionally, a POSITA would be motivated to make Van Dijk's frame members parallel as taught by Schaaf to provide better spacing between seats and accessories and to achieve a predictable, stable, collapsible frame.
    • Expectation of Success (for §103 grounds): Success was expected as both references used conventional design components, and applying Van Dijk’s mounting technology to Schaaf’s frame configuration represented a straightforward integration of known elements.

Ground 3: Claims 1-17 and 19-22 are obvious over Liao in view of Schaaf.

  • Prior Art Relied Upon: Liao (Patent D593,459) and Schaaf (Patent 6,209,892).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Liao disclosed a double stroller, but its front seat attachment was undesirable because it included its own separate wheel and support frame, adding cost, complexity, and weight. Schaaf taught a more elegant and stable inline double stroller that supported the front seat close to the main front wheels without needing an extra wheel assembly. The combination involved modifying Liao's design by adopting Schaaf's simpler front seat support structure. This modification would result in an inline descending configuration as claimed.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings to improve Liao’s design by removing the cumbersome and costly extra wheel assembly from the front seat attachment. Adopting Schaaf’s approach would create a simpler, lighter, and more cost-effective double stroller that was still stable. This modification was a predictable design improvement to solve the known problems with Liao's design.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as the modification involved simplifying a design by substituting a complex component with a known, simpler alternative to achieve the predictable result of a more efficient and manufacturable double stroller.

4. Key Claim Construction Positions

  • "releasably connect" / "releasably attach": Petitioner adopted the explicit definition from the ’231 patent’s specification, meaning a connection capable of being connected and disconnected by the user without special tools or skills.
  • "substantially parallel": Petitioner adopted the Patent Owner's asserted litigation position, construing the term to mean "the parallel relationship is not a strict relationship, such that some deviation from exactly parallel is permitted." This construction was central to Petitioner's argument that the priority applications, which show perfectly in-line members, do not support this limitation.

5. Key Technical Contentions (Beyond Claim Construction)

  • Lack of Priority for "Substantially Parallel" Limitation: Petitioner’s primary technical contention, which underpins Ground 1, was that the ’231 patent was not entitled to any of its claimed priority dates. Petitioner argued that the limitation "the front wheel support portion and the handle portion are substantially parallel" was added via an Examiner’s amendment and lacked written description support in any priority application. The drawings in the priority applications allegedly depicted these portions as being perfectly in-line (collinear from a side view), which Petitioner argued is the antithesis of parallel, thereby making the effective filing date of the challenged claims July 29, 2022.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 and 19-22 of the ’231 patent as unpatentable.