PTAB

IPR2025-01105

Monahan Products, LLC (dba UPPAbaby) v. Baby Jogger, LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Seat Attachment for a Stroller
  • Brief Description: The ’869 patent discloses a seat attachment accessory, or conversion kit, designed to convert a single-seat stroller into a double-seat stroller. The attachment comprises separate left and right portions that removably connect to the stroller frame to support a second seat in either a forward or backward-facing position.

3. Grounds for Unpatentability

Ground 1: Claims 1-30 are obvious over Liao

  • Prior Art Relied Upon: Liao (U.S. Design Patent No. D593,459).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Liao, which was not considered during the original prosecution, discloses all limitations of the challenged claims. Liao’s figures illustrate a convertible single-to-double stroller with a seat attachment that is strikingly similar to the one disclosed in the ’869 patent. This attachment includes separate left and right portions, each with a connector portion for removably connecting to the stroller frame adjacent the front wheels and a seat support element for removably connecting a second seat. Petitioner asserted that Liao’s latch mechanism renders the connection removable, and its figures show the seat being mounted in both forward and backward positions.
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner argued that to the extent any minor modification was needed, such as making a seat connection explicitly reversible if not already disclosed, a Person of Ordinary Skill in the Art (POSITA) would have been motivated to do so to provide the common and desirable option for a child to face the caregiver or face forward.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success as any modifications would involve simple, conventional design components well within the skill of a POSITA.

Ground 2: Claims 1-30 are obvious over Stopp

  • Prior Art Relied Upon: Stopp (Spanish Patent ES 2253093).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stopp discloses a single stroller that can be converted into a double stroller using a seat attachment. Independent claims 1 and 24 are met by Stopp’s seat attachment (3), which has separate left and right portions that connect to the stroller frame. Each portion comprises a connector rod (4) that inserts into a bushing (2) on the frame adjacent the front wheels, and a seat support element (a "crab-claw" feature) that removably connects a seat. Stopp illustrates various seats, including bassinets and stroller seats, being attached.
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner contended that Stopp teaches that its underlying stroller is of a conventional nature, and a POSITA would have understood that conventional strollers at the time included features like reversible seats, folding mechanisms, and secure releasable seat connections.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in implementing any minor variations because they involve integrating well-known, conventional stroller features into Stopp’s disclosed system.

Ground 3: Claims 13 and 14 are obvious over Stopp in view of Chen, Wun, and Lake

  • Prior Art Relied Upon: Stopp (Spanish Patent ES 2253093), Chen (Application # 2010/0013281), Wun (Application # 2006/0082104), and Lake (Application # 2008/0150247).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that, to the extent Stopp in view of Chen is found not to disclose the folding mechanisms of claim 13 or the releasable button/tab connection of claim 14, these features would have been obvious to add from other prior art. Wun was cited for its explicit disclosure of a folding mechanism for compact storage of a stroller. Lake was cited for its teaching of a releasable connection using a push-button and latch system to securely attach a child carrying unit to a stroller frame and prevent inadvertent detachment.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings of Wun and Lake with Stopp to improve its functionality with desirable, conventional features. Incorporating a folding mechanism from Wun would make the stroller easier to store and transport. Adding a secure, releasable connection taught by Lake would enhance safety by preventing the seat from unintentionally detaching.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success as all references disclose conventional stroller systems, and integrating these known components and functionalities would be a straightforward application of known design principles.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Liao in view of Chen, and Stopp in view of Chen, arguing that Chen’s disclosure of receptacles and inserts for removably and reversibly mounting a seat would have been an obvious modification to the primary references if they were found to lack such a feature.

4. Key Claim Construction Positions

  • Petitioner stated that for the purposes of this inter partes review (IPR), it applies the claim constructions proposed by the Patent Owner in co-pending district court litigation.
  • Specifically, the term "adjacent" is construed to mean "next to" or "nearby," and the term "closer" is construed to mean "being nearer in space."

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-30 of the ’869 patent as unpatentable.