PTAB

IPR2025-01106

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

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Convertible Single-to-Double Seat Stroller Attachment
  • Brief Description: The ’550 patent discloses a seat attachment accessory or conversion kit for a stroller that permits the conversion of a single-seat stroller into a double-seat stroller. The invention is centered on a second seat attachment, comprising left and right seat support elements, that releasably connects to the stroller frame to hold a second child.

3. Grounds for Unpatentability

Ground 1: Obviousness over Liao - Claims 1-6 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, a design patent for a convertible single-to-double stroller, discloses or renders obvious all limitations of the challenged claims. Liao’s figures illustrate a stroller with a frame, wheels, a first (rear) seat, and a second seat attachment for a front seat. Petitioner contended that Liao shows this second seat attachment coupled at a vertical position substantially below the first seat and closer to the front wheels. The attachment includes separate left and right seat support elements, each with a connector portion for latching to the stroller frame and a seat connector for engaging a second seat. Petitioner further asserted that the various seat types shown in Liao (e.g., baby seat, car seat, bassinet) imply the seat is releasably connected to the support elements, meeting the limitations of dependent claims 2-5. For claim 6, the latching mechanism shown in Liao was argued to be a form of snap, friction fit, or locking tab.
    • Motivation to Combine: Not applicable for a single-reference ground. However, for any element not explicitly shown (e.g., the precise nature of the "releasably connected" feature), Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to make such connections releasable without special tools.
    • Expectation of Success: This motivation, Petitioner claimed, stemmed from the simple desire to facilitate easier transportation and storage of the stroller system. A POSITA would have had a high expectation of success because such modifications would involve straightforward, conventional stroller components and well-understood design principles.

Ground 2: Obviousness over Liao in view of Chen and Sweeney - Claims 1-7 are obvious over Liao in view of Chen and Sweeney.

  • Prior Art Relied Upon: Liao (U.S. Design Patent No. D593,459), Chen (Application # 2010/0013281), and Sweeney (Patent 6,585,284).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground was presented as an alternative in case Liao alone was found not to teach every limitation of claims 1-6, and as the primary ground against claim 7. Petitioner asserted that Chen teaches a stroller with receptacles for releasably inserting seat connectors, which explicitly permits a seat to face either forward or backward. Sweeney was cited for its disclosure of a height-adjustable rear seat, which can be moved up and down on the stroller frame to provide the rear passenger with a view over the front seat. The combination, Petitioner argued, supplies any missing element from Liao. Specifically, Chen’s reversible seat functionality teaches the "forward or backward position" limitation, and Sweeney’s height-adjustable seat provides an explicit teaching of seats at different vertical positions ("substantially below").
    • Motivation to Combine: A POSITA would combine Liao’s convertible stroller design with Chen’s reversible seat functionality to enhance user convenience and versatility, allowing parents to arrange seats as desired. A POSITA would be further motivated to incorporate the height-adjustable rear seat taught by Sweeney to improve the passenger experience, a known goal in stroller design. This combination would inherently result in the front seat being positioned substantially below the rear seat, directly teaching a key limitation of the challenged claims.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success in making this combination. All three references relate to stroller systems using conventional components, and integrating their respective features would have been a straightforward application of known components and skills.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 1-6 over Stopp (Spanish Patent Pub. ES 2253093) alone, and against claims 1-7 over Stopp in view of Chen and Sweeney, relying on analogous arguments regarding convertible stroller design and user-centric features.

4. Key Claim Construction Positions

  • “releasably connected” / “releasably attached”: Petitioner adopted the patent’s explicit definition, which states the term “means the connection is not a permanent connection and that the connection is capable of being connected and disconnected by the user of the stroller 10 without requiring special tools or special skills.” This definition was central to arguments that the prior art connections, such as latches, met this limitation.
  • “closer”: Petitioner applied the construction proposed by the Patent Owner in related litigation, meaning “being nearer in space.” This was used to map the relative positions of the first and second seats to the handle and front wheels as shown in the prior art.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-7 of Patent 9,403,550 as unpatentable.